Interpretation ID: aiam1585
Attorney at Law
The Chadamy Corporation
5241 Southwyck Blvd.
Toledo
OH 43614;
Dear Mr. Vidoli: This responds to your August 8, 1974, request for our opinion of th legality of the manufacture and sale of a device which frustrates the ignition function of seat belt assemblies in 1974 model passenger cars. The device, to be manufactured by the Chadamy Corporation under the name 'Buzz-Off', consists of two devices that are inserted in the ends of a seat belt assembly to simulate a buckling action.; The National Highway Traffic Safety Administration has promulgated n safety standard regulating the manufacture of your product. A standard does exist, however, which specifies requirements for occupant restraint systems. If one of your devices were installed in a vehicle prior to its first purchase for purposes other than resale, causing the interlock system not to be in compliance with the occupant crash protection standard, the person installing the device or offering the vehicle for sale would be in violation of Section 108(a)(1) of the National Traffic and Motor Vehicle Safety Act. That section prohibits the manufacture for sale, sale, or offer for sale of any motor vehicle or item of motor vehicle equipment that does not comply with applicable safety standards in effect on the date of their manufacture.; I would like to point out, that we estimate 10,000-15,000 individual died needlessly during 1973 because they were not wearing their seatbelts. Obviously, any device which disconnects a seat belt interlock could gravely increase the risk faced by the occupants of the motor vehicle. We cannot agree with your conclusion that people would not utilize your device to frustrate the interlock in highway driving.; I would also like to point out the recent Congressional action in whic the House of Representatives passed a law which would prevent a requirement for ignition interlock systems in future passenger cars. The final form of this law, pending Senate action, is not clear.; Yours truly, Richard B. Dyson, Acting Chief Counsel