Interpretation ID: aiam3176
Director
Vehicle Safety Programs
American Motors Corporation
14250 Plymouth Road
Detroit
MI 48232;
Dear Mr. Schang: This responds to your recent letter requesting an interpretation of th warning system requirements for seat belts in Federal Motor Vehicle Safety Standard No. 208. The buckles of driver lap belts in all AMC vehicles and most Jeep vehicles are equipped with switches that prevent the audible belt use warning system from operating when the driver turns the ignition on after having fastened his or her lap belt. You ask whether the standard allows removal of the switch and associated wiring. The effect of this step, which would result in a savings of about $1.50 per vehicle, would be that the warning would operate regardless of whether the driver has fastened his or her lap belt. You also ask that your letter be considered a petition for rulemaking if this removal is not permissible.; Paragraph S7.3 of the standard requires a seat belt warning system tha activates a 4 to 8-second warning light when the vehicle's ignition switch is moved to the 'on' or 'start' position (condition 'a'), and a 4 to 8-second audible signal when condition 'a' exists and the driver's lap belt is not fastened (condition 'b'). Under your proposal, the audible signal would be activated when both conditions exist. However, it would also be activated when condition 'a' alone exists.; The functioning of the audible signal when condition 'a' only exists i not permissible under the standard. The rulemaking notices which led to adoption of the current requirement stated that the agency's intent was that the audible signal operate if the driver's lap belt is not in use. The agency expressed that same intent in the standard by specifying the light to function when condition 'a' existed and the audible signal when both conditions 'a' and 'b' existed. To interpret the standard to permit the signal to operate when condition 'a' only existed would be to render purposeless the specification of condition 'b'.; Further, the agency denies your petition to amend FMVSS 208 to permi operation of the audible signal when condition 'a' only exists. A greater limitation was placed on the operation of the audible warning signal in consideration of the irritation factor associated with the signal but not with the light. To provide a reminder and incentive for safety belt use and to avoid subjecting the conscientious belt user to having to hear an audible reminder to do something that he or she has already done, the agency specified that the signal would not function if the driver's safety belt were fastened.; In light of studies concerning the value of a properly designed bel use warning system in improving the rate of belt use, the agency is contemplating including a proposal to amend the FMVSS 208 warning requirements when it issues its forthcoming notice of proposed rulemaking on seat belt comfort and convenience. We would welcome your views on the proposal following its announcement.; Sincerely, Frank Berndt, Chief Counsel