Interpretation ID: 07-007036as 201 armrest

Ms. Joan Ward

P.O. Box 5812

Knoxville, TN 37928

Dear Ms. Ward:

This responds to your letter asking whether S5.5.1 of Federal Motor Vehicle Safety Standard (FMVSS) No. 201, Occupant Protection in Interior Impact, only appl[ies] to the armrest on the door panel or does it apply to any armrest in the pelvic area, such as the armrest in the center of the vehicle between the front seats? Our answer is that each armrest, including an armrest located in the center of the vehicle between the front seats, must meet the requirements of S5.5.1.

By way of background, the National Highway Traffic Safety Administration (NHTSA) is authorized to issue FMVSSs that set performance requirements for new motor vehicles and items of motor vehicle equipment (see 49 U.S.C. Chapter 301). NHTSA does not provide approvals of motor vehicles or motor vehicle equipment.  Instead, manufacturers are required to self-certify that their products conform to all applicable safety standards that are in effect on the date of manufacture. NHTSA selects a sampling of new vehicles and equipment each year to determine their compliance with applicable FMVSSs.  If our testing or examination reveals an apparent noncompliance, we may require the manufacturer to remedy the noncompliance, and may initiate an enforcement proceeding if necessary to ensure that the manufacturer takes appropriate action.

S5.5 of FMVSS No. 201 specifies requirements for armrests that are provided in a vehicle. The requirements in paragraph S5.5.1 apply to armrests generally, and the standard does not differentiate between an armrest in the center of a vehicle and an armrest on a side door panel. Accordingly, it is our opinion that an armrest located between the front seats of a vehicle is subject to the requirements of FMVSS No. 201.

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

Sincerely yours,

Anthony M. Cooke

Chief Counsel

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d.11/20/08