Interpretation ID: nht90-2.18

TYPE: INTERPRETATION-NHTSA

DATE: 04/19/90

FROM: CARL HEINZ FABER -- MERCEDES BENZ OF NORTH AMERICA

TO: BARRY FELRICE, ASSOCIATE -- ADMINISTRATOR FOR RULEMAKING NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION

TITLE: ARMREST STORAGE COMPARTMENT

ATTACHMT: ATTACHED TO LETTER DATED 06/14/90 FROM PAUL JACKSON RICE -- NHTSA TO KARL HEINZ FABER; A35; STANDARD 20

TEXT: In the near future, Mercedes-Benz vehicles will come equipped with new armrests between the two front and, where applicable, two rear seating positions. The new design will have a built-in compartment that can accommodate car phone storage. It will be covered by a lift-up lid that will afford easy access to the phone for the driver so that he can keep his basic attention on driving without having to deal with a small latch. A blue-print of the armrest is enclosed.

Our new armrest complies with the requirements of Standard 201 S3.5.2 which state that armrests that fold into the seat back or between two seat backs shall "Be constructed of or covered with energy-absorbing material."

In addition, we believe that the center armrest lid is not covered by S3.3 and S3.3.1, based on the fact that S3.3 (Interior Compartment Doors) is very specific as to the components and the locations of compartment doors which must be tested. It specifi es neither the armrest itself nor a location between designated seating positions as being subject to S3.3.1.

Based on the above and in an effort to remove the car phone from an exposed interior position where it could interfere with the driver's use of controls, potentially be contacted by the head, or be insufficiently secure in case of collision, we will init iate production of the above described phone holder/armrest in the very near future.

If any member of your staff would like additional information, they should please contact Thomas Baloga in our Safety Engineering department at (201) 573-2616.

Enclosure