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Interpretation ID: 24473.drn

J. C. Powell, Esq.
Powell & Majestro PLLC
405 Capitol Street, Suite P-1200,
P.O. Box 3081
Charleston, WV 25331

Dear Mr. Powell:

This responds to your letter to Stuart Seigel, Safety Compliance Engineer at the National Highway Traffic Safety Administration (NHTSA), requesting written confirmation that there is no "Federal Regulation requiring manufacturers to equip manual transmission vehicles with a starter interlock, also known alternatively as a neutral safety switch, starter safety switch, clutch safety switch, and clutch pedal position switch." Since you are asking for a legal opinion with respect to the Federal Motor Vehicle Safety Standards (FMVSSs) (49 CFR Part 571), I am responding on Mr. Seigels behalf. Your understanding that no FMVSS requires a starter interlock for manual transmission vehicles is correct.

As you are aware, Standard No. 102, Transmission shift lever sequence, starter interlock, and transmission braking effect (49 CFR 571.102), applies to passenger cars, multipurpose passenger vehicles, trucks, and buses. Standard No. 102 specifies the requirements for the transmission shift lever sequence, a starter interlock, and for a braking effect of automatic transmissions, to reduce the likelihood of shifting errors, starter engagement with vehicle in drive position, and to provide supplemental braking at speeds below 40 kilometers [25 miles] per hour.

Paragraph S3.1.3 specifies a starter interlock only for vehicles with automatic transmissions. Standard No. 102 specifies requirements for manual transmission vehicles at paragraph S3.2 Manual transmissions. Paragraph S3.2 does not include a requirement for starter interlocks.

Please note that Standard No. 102 has never included a requirement for starter interlocks on manual transmission vehicles. Hence, in 1989 and in 1990, there was no manual transmission starter interlock requirement in Standard No. 102.

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

Jacqueline Glassman
Chief Counsel