Interpretation ID: 1983-3.14

TYPE: INTERPRETATION-NHTSA

DATE: 10/27/83

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Mazda (North America) Inc.

TITLE: FMVSS INTERPRETATION

TEXT:

NOA--30

Mr. H. Nakaya Office Manager Mazda (North America), Inc. 23777 Greenfield Road, Suite 462 Southfield, Michigan 48075

Dear Mr. Nakaya:

This responds to your letter of August 25, 1983, requesting an interpretation of the requirements of Standard No. 201, Occupant Protection in Interior Impact. Your specific questions concern the application of the requirements of S3.5.1(b) of the standard to an armrest.

The answers to your four questions are as follows:

A) The requirements of S3.5.1(b), as with the requirements of S3.5.1(a), apply to the whole area of an armrest. In contrast, the requirements of S3.5.1(c) only apply to a part of an armrest (i.e., the portion of the armrest within the pelvic impact area).

B) See answer to A.

C) The agency does not give prior approval to specific designs. It appears, however, that your design would not comply, since apparently the armrest will not deflect or collapse to within 1.25 inches of a rigid test panel surface without permitting contact with any rigid material, in this case the power window switch. In addition, the power window switch apparently does not have a minimum vertical height of not less than one inch. It is difficult to provide you with a definitive answer since section A-A of your drawing appears to be drawn to a different scale than the scale shown in the lower left corner of your drawing.

D) It appears from your drawing that even if the requirements of S3.5.1(b) were amended, as you suggested, to limit their application to the pelvic impact area of the armrest, the design would not comply since the power window switch area of the armrest is within the pelvic impact area. Rather than seeking an amendment to the standard, you may want to consider modifying your design so that it will comply with either 3.5.1(a) or (c) of the standard.

If you have any further questions, please let me know.

Sincerely,

Frank Berndt Chief Counsel

August 25, 1983

Mr. Frank Berndt Chief Counsel National Highway Traffic Safety Administration 400 Seventh Street, S.W. Washington, D.C. 20590

RE: Interpretation of FMVSS 201, Occupant Protection in Interior Impact

Dear Mr. Berndt:

Mazda submits this letter to request an interpretation of the requirements for standard S3.5.1.(b) of FMVSS 201, Occupant Protection in Interior Impact.

Mazda is developing a new model in which the armrest, by design, should meet the standard S3.5.1.(b). It is difficult for the design to meet standard S3.5.1.(a) or (c). The requirement states, "It shall be constructed with energy-absorbing material that defects or collapses to within 1.25 inches of rigid panel surface . . ."

Our questions are as follows:

A) Is this requirement applied to the whole area of an armrest or part of an armrest?

B) If this requirement applies to part of an armrest, what is the area that it applies to?

C) Does Mazda's design conform to standard S3.5.1(b)? (See attached sketch)

D) If Mazda's design does not conform to standard S3.5.1.(b), what kind of amendment is required? Example: At least the pelvic impact area has to meet the requirement.)

We would appreciate your interpretation with regard to this matter at your earliest convenience.

Thank you.

Sincerely,

H. Nakaya Office Manager

HN/ab

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