Interpretation ID: nht80-2.25

DATE: 04/30/80

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Sleek-Craft Boats

TITLE: FMVSS INTERPRETATION

TEXT:

APR 30 1980

Mr. Warren Robbins Manager, Automobile Division Sleek-Craft Boats P.O. Box 3563 Santa Fe Springs, California 90670

Dear Mr. Robbins:

This responds to your recent letter requesting an interpretation of Safety Standard No. 214, Side Door Strength, as it would apply to a new sports car that your company intends to market. You state that the side doors of this vehicle design can meet the "intermediate" and "peak" crush resistance requirements of the standard but not the "initial" crush resistance requirement because of an outer fiberglass veneer component of the door. You ask whether the vehicle can be exempt from this "initial" requirement since the door can withstand the maximum forces required by the standard.

The answer to your question is no. Safety Standard No. 214 requires doors to comply with all three stages of the crush resistance requirements and there is no provision for an averaging of the crush resistance abilities. Although inboard mounted structures may be effective in preventing intrusion if the door has a large cross section, with a correspondingly large distance between the protective structure and the inner panel, the standard reflects a determination by the agency that doors afford the greatest protection panel as possible. Additionally, the "initial" crush resistance requirements are necessary to ensure that the entire door system is structurally sound. This is particularly important because of the risk of occupant ejection if door hinges and latches separated during an accident, allowing the door to fly open.

Although the relief you seek cannot be granted by interpretation of Safety Standard No. 214, there are provisions for temporary exemptions from Safety Standards or portions of safety standards under certain circumstances; such as economic hardship. I am enclosing a copy of the regulation governing temporary exemptions for your information (49 CFR Part 555). After reviewing this regulation, you may wish to petition the agency for a temporary exemption from the "initial" crush resistance requirements of the standard. The regulation explains the procedures you must follow.

If you have any further questions, please contact Hugh Oates of my office at 202-426-2992.

Sincerely,

Frank Berndt Chief Counsel

Enclosure

March 13, 1980

National Highway Safety Administration Washington, D.C. 20590

Attention: Office of Chief Counsel

Re: FMVSS #214

Gentlemen:

Our firm is in the process of building a limited production sports car. We expect the automobile to comply with all Federal Safety Standards. As the automobile is not designed, we anticipate a problem with FMVSS-214, "Side Door Strength." The purpose of this letter is to secure an opinion from the Office of Chief Counsel before the actual testing is done.

Definition of anticipated problem:

The standard required the structure of the door to withstand 2250 pounds of applied pressure over the initial 6 inches of travel, (53.1). We foresee no problem in complying and exceeding 53.2 and 53.3 of the standard.

The problem with compliance with 53.2 is that the side doors are 10" thick. The outer-most 5 inches are decorative fiberglass veneer and are used as air ducts for the radiators which are mounted in the rear.

The inner 5" of the door constitute the frame work and intrusion protection. This protection is very substantial consisting of a triangularly shaped structure constructed from .120 wall 1020 steel. The accompanyiny drawing clarifies this intrusion barrier's location and mounting relative to other frame structures. As the drawing demonstrates, our intent is to provide very substantial protection from side impacts.

The intrusion barrier (c), is supported vertically by the door support (d), which itself is a substantial member (11" x 2" channel, .090 thick 1020 mild steel). The barrier is prevented from entry into the passenger compartment by a roll bar in the rear and roll hoop in front. These members are also of .120 wall 1020 mild steel and are cross braced from the platform frame.

Opinion requested:

Petitioner, Performance Products Inc., requests that the requirements of FMVSS #214 section 53.1 be waived and that the automobile produced by Performance Products be deemed in compliance if the provisions of 53.2 and 53.3 of FMVSS #214 are successfully performed.

Thank you for your consideration.

Kindest regards,

Warren Robbins Manager Automobile Division

Enclosure

WR/ca