Interpretation ID: aiam1401
House of Representatives
Washington
DC 20515;
Dear Mr. Sullivan: In response to your February 11, 1974, request in behalf of constituent, Mr. Frank Mills of Saint Louis, I would like to discuss the legal implications of modifications to the ignition interlock system on 1974 model passenger cars. I am not familiar with the booklet to which Mr. Mills refers.; The interlock is one part of Standard 208, which like any other safet standard issued under the National Traffic and Motor Vehicle Safety Act of 1966, applies to new vehicles only. Once a vehicle is sold for purposes other than resale and the buyer takes delivery, he may modify the system or legally have the system modified by an automobile repair service to accommodate circumstances, such as physical incapacity, which make use of the belts unwise or inconvenient.; Whether or not a dealer's disconnection of an interlock system unde any given specified set of circumstances would be legally permitted is a conclusion which the courts would determine if called upon to decide such an issue. The position of this agency is that any act by a dealer to disconnect an interlock system which could be related to a sales transaction or the introduction into interstate commerce of a motor vehicle is prohibited. In this respect, we support H.R. 5529 which would prohibit any motor vehicle manufacturer, distributor, dealer, or repair business from removing or rendering inoperative any Federally-required safety equipment, including interlocks, from new or used vehicles. The prohibition would not apply to vehicle owners.; I have taken the liberty of forwarding a copy of this letter to Mr Mills at his St. Louis address to assure receipt of the information by February 21, 1974.; Sincerely, Lawrence R. Schneider, Chief Counsel