Ms. Marine Jacotot
7. rue Louis Heuiliez BP 70209
79142 CERIZAY Cedex
Dear Ms. Jacotot:
This is in response to your e-mail regarding free motion headform (FMH) impact test requirements for upper interior components in Federal Motor Vehicle Safety Standard (FMVSS) No. 201, Occupant Protection in Interior Impact (S6.3), as they relate to your companys retractable hardtop (RHT) roof system. Specifically, you seek confirmation of your interpretation that by excluding any target located on a convertible roof frame or on a convertible roof linkage mechanism, S6.3(a) also excludes any target on a decorative trim located such that during a FMH test, the trim would be between the forehead of the headform and the roof linkage mechanism or convertible roof frame. Based on the information you provided in emails on October 17, 2007 and December 13, 2007, and the analysis below, the National Highway Traffic Safety Administration (NHTSA) disagrees with your interpretation as it applies to the Peugeot 206 CCs RHT roof system.
S6.3(a) of FMVSS No. 201 provides that a vehicle need not meet the requirements of S6.1 through S6.2 (the FMH impact requirements) for any target located on a convertible roof frame or a convertible roof linkage mechanism. Convertible roof frame is defined in S3 as the frame of a convertible roof. Convertible roof linkage mechanism is defined in S3 as any anchorage, fastener, or device necessary to deploy a convertible roof frame.
In an April 5, 2002 letter we sent your company, we interpreted the S6.3 exclusion as it applies to RHT roof systems and hardtops for convertibles. NHTSA determined that with the exception of those components required to raise and lower the top or to latch it into position, RHT roof systems and detachable hardtops for convertibles must meet the FMH impact requirements of FMVSS No. 201.
Previously addressing the application of the FMH impact test requirements to convertible roof systems, in an April 1998 Federal Register notice denying petitions for reconsideration, NHTSA rejected a request to modify the definition of convertible roof frame to include RHTs. We explained that the S6.3 exclusion of convertible roof frames and linkage mechanisms from the FMH impact requirements existed because the presence of a countermeasure such as padding would interfere with the frame and linkage mechanisms movement. We further reiterated that rigid convertible tops could produce head injuries and that the agency believed that protection should be provided for all the hard areas inside a vehicle unless it is not practicable to do so. 63 Fed. Reg. 19839, 19840. NHTSA noted that the petitioner did not submit any data indicating that convertible hardtops cannot be made as flexible as a conventional roof structure. The agency determined that since convertible roof frames and linkage mechanisms are excluded from FMH impact tests, the design of the remainder of the convertible hardtop roof should not present additional compliance difficulties. Id.
The photographs and information you sent us was for the Peugeot 206 CCs RHT roof system. This vehicles RHT roof system consists of two moving, rigid panel sections. This RHT roof system retracts and deploys by the movement of two metal arms along the length of both panels of the roof on both sides, in the longitudinal direction. The two panels are connected by the movable metal arms, and by two joints located at the outer edges of the rigid panels. In your photographs, you have denoted these two joint areas, which consist of a metal side of the joint (facing the exterior of the vehicle) and a plastic side of the joint (facing the interior of the vehicle), as the roof joint mechanisms. The user secures the RHT to the vehicle frame by manually locking two front latch mechanisms, which each consist of a fixed striker on the A-pillar, a hook on the RHT, and a handle. The edges of the roof closest to the movable metal arms have a plastic trim that runs along the length of both sides of the rigid roof panels. The trims purpose is to cover the movable metal arms when the roof is deployed in the coupe configuration. Since the trim is linked to the roof, the trim moves when the roof moves, and thus is stowed with the roof when the RHT is in the convertible configuration. The two front latch mechanisms and the two roof joint mechanisms appear to be components necessary to raise and lower the top or to latch it into position. Thus, under S6.3, the vehicle need not meet the FMH impact requirements for any target located on these components.
Because the trim moves and stows with the roof panels (and not with the movable arms), it appears that the trim is more a part of the roof than a part of the components necessary to raise and lower the roof or to latch it into position. It does not appear to us that the presence of a countermeasure such as padding would interfere with the trims movement, or that the trim cannot be made as flexible as the rest of the roof structure. Accordingly, while the roof joint mechanisms and front latch mechanisms are excluded from being targets for the FMH impact tests, the plastic trim on the Peugeot 206 CCs RHT roof system that covers the metal bars would not be excluded as a target in the FMH impact tests. This trim covering the movable metal arms is distinguished from any plastic pieces on the front latch mechanisms or roof joint mechanisms, which we do consider excluded from being a target in the FMH impact tests, because we consider those plastic pieces to be parts of the front latch mechanisms and roof joint mechanisms.
We hope this answers your questions. If you have any further questions, please do not hesitate to contact Sarah Alves of my staff at (202) 366-2992.
Anthony M. Cooke