Interpretation ID: nht92-9.15

DATE: February 10, 1992

FROM: Jeff Ruff -- Director of Fleet / Government Sales, The Braun Corporation

TO: Office of the Chief Counsel, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 3/16/92 from Paul Jackson Rice to Jeff Ruff (A39; Std. 208)

TEXT:

Several months ago I wrote you voicing my concern with FMVSS 208 and how it affects the transportation needs of the physically challenged. My concern in that letter was the head clearance needed for wheelchair passengers and our inability to cut the "B" pillar support brace from the chassis.

Since my first letter, we at The Braun Corporation have been busy adapting the new vehicles to the needs of our customers. One of our more recent observations concerns the location of the front passenger shoulder belt anchorage point. As you will see in the pictures, the original anchorage point for this vehicle was above the front side cargo door. Because the transportation needs of the physically challenged sometimes demand extended doors for added head clearance, this anchorage point must be moved. The obvious choice for relocating this is at the "B" pillar. (Please note picture.) However, when relocating the anchorage point the OEM FMVSS 208 certification is voided.

Please advise us as to how our industry can adapt to this requirement. I would appreciate a response to not only this letter, but the letter dated October 30, 1991.

Your immediate response to this matter would be greatly appreciated.