Interpretation ID: 06-003753as

Gerald Plante, General Manager

Fuji Heavy Industries U.S.A., Inc.

c/o Subaru of America

Subaru Plaza

P.O. Box 6000

Cherry Hill, NJ 08034-6000

Dear Mr. Plante:

This is in response to your letter regarding Federal Motor Vehicle Safety Standard (FMVSS) No. 201, Occupant protection in interior impact, as applied to interior compartment doors. You ask whether the top segment of an L-shaped center console would be considered an interior compartment door for the purposes of Standard 201, paragraph S5.3. As discussed below, our analysis of the description and photographs of the console you provided in your letter leads us to conclude that it would be considered a door for purposes of paragraph S5.3.

FMVSS No. 201 sets forth, among other things, requirements for interior compartment doors (S5.3). S5.3 states: Each interior compartment door assembly located in an instrument panel, console assembly, seat back, or side panel adjacent to a designated seating position shall remain closed when tested with the demonstration procedures in the standard.

49 CFR 571.3(b) defines interior compartment door as any door in the interior of the vehicle installed by the manufacturer as a cover for storage space normally used for personal effects. You state in your letter that the console incorporates a cup holder and space for other objects such as CDs, etc. On top of the console is an armrest which can pivot to either cover the storage space in the console (as shown in photograph #1 of your letter) or expose it (as shown in photograph #2).

You ask if the armrest is an interior compartment door which must comply with the requirements in paragraph S5.3. Our answer is yes. First, as the center console is designed for the storage of personal effects, the lift-up armrest which serves as a cover would be considered an interior compartment door. Second, as this is part of the console

assembly, it is subject to paragraph S5.3 as it is located in an instrument panel, console assembly, seat back, or side panel adjacent to a designated seating position. Therefore, it is subject to the requirements of S5.3 of FMVSS No. 201.

If you have any additional questions, contact Ari Scott of my staff at (202) 366-2992.

Sincerely,

Anthony M. Cooke

Chief Counsel

ref:201

d.11/2/06