Mr. John A. Griffiths
510G Bellfield Drive
Newport News, VA 23602

Dear Mr. Griffiths:

This responds to your request for an interpretation whether the Federal Motor Vehicle Safety Standards specify for a manual transmission vehicle, a "neutral safety switch," or other means to prevent starting of the vehicle unless the clutch is fully depressed. The answer is no.

Standard No. 102, Transmission shift lever sequence, starter interlock, and transmission braking effect, specifies starter interlocks for automatic transmission vehicles, but not for manual transmission vehicles. (See S3.1.3.) None of the other safety standards specify that motor vehicles include a device of the type you describe, or specify means to prevent starting of a manual transmission vehicle unless the clutch is depressed.

I hope that this information is useful. If you have any further questions, please contact Dorothy Nakama of my staff at (202) 366-2992.

Sincerely,

John Womack Acting Chief Counsel

ref:102 d:6/8/94