Interpretation ID: nht68-1.41

DATE: 06/10/68

FROM: WILLIAM HADDON -- FEDERAL HIGHWAY ADMINISTRATION

TO: HARRY F. BARR -- VICE PRESIDENT ENGINEERING STAFF GENERAL MOTORS TECHNICAL CENTER GENERAL MOTORS CORPORATION

TITLE: NONE

TEXT: Dear Mr. Barr:

The interpretations of Motor Vehicle Safety Standard No. 105 regarding cable type and bar type brake controls for driver training vehicles described in your letter of May 24 are quite correct. Motor Vehicle Safety Standard No. 105 does not apply to the installation of add-on driver training brake controls following retail sale of a new car. In the case of installation of add-on driver training brake controls in new cars prior to retail sale, the following apply:

a. Motor Vehicle Safety Standard No. 105 does not apply to the add-on brake control itself; however, the installation of such controls must not affect compliance of the regular hydraulic brake system to Motor Vehicle Safety Standard No. 105.

b. Following installation of a mechanical-type add-on brake control, the installing dealer is responsible for determining that compliance of the regular brake system is not impaired by verifying that the add-on control does not interfere with normal driver access to and application of the regular brake pedal.

Although endorsing your understanding of the requirement imposed by Motor Vehicle Safety Standard No. 105, I am not endorsing these brake devices or passing on their safety from a crash standpoint.

I appreciate your interest in driver education and training and your efforts to further traffic safety through this program.

Sincerely,