Mr. Myungwon Park
Chief Manager
Daewoo Certification
Daewoo Motor Company

Dear Mr. Park:

This is in response to your facsimile transmission of June 25, 1996, in which Daewoo Motor Corporation (Daewoo) asks several questions regarding the design of a door panel. In particular, your letter seeks information relating to an armrest integrated in this door panel and the requirements of Standard No. 201, Occupant Protection in Interior Impact.

Your facsimile transmission contained four questions and several drawings depicting the interior door panel in a side view and in section view. The questions are repeated below followed by the individual answers:

  1. We would like to know whether or not the door trim would follow the regulations for armrest? (The armrest is integrated so we would like to know your view)

    The term "armrest" is not defined in Standard 201. The basic meaning of "armrest" in Webster's New Third International Dictionary is "a support for the arm." Therefore, the question of whether the door trim depicted in your drawings must meet the requirements for armrests contained in S3.5 of Standard 201 is dependent on whether the door trim is likely to be used by occupants to rest their arms during normal use of the vehicle. While the drawings provided in your facsimile transmission do not provide dimensions for the width of the horizontal sections of the door trim, it appears as if portions of this trim would be used by occupants to rest their arms. Therefore, these portions of the door trim would be required to meet S3.5 of Standard 201. The agency cannot, however, provide your company with an opinion regarding compliance of this particular design as NHTSA does not give prior approval to specific designs.

  2. If question 1 is related to the regulations, where would the limit for the armrest at the door trim section?

    Standard 201 does not specify where an armrest must be located. Under the Standard an armrest must conform to one of the requirements found in S3.5.1. If a manufacturer chooses to comply with Standard 201 by conforming to the requirements of S3.5.1(c), an armrest must, when measured vertically in side elevation, provide at least 2 inches of continuous coverage in the pelvic impact area along at least 2 inches of its length.

  3. Whether or not the groove section shown below would violate FMVSS 201?

    Provided that the armrest conforms either to S3.5.1.(a), (b) or (c), the groove section depicted in your drawings would not violate Standard 201. If your inquiry is directed specifically to the requirements of S3.5.1(c), it appears from the drawings provided with your request that in this instance the groove does not result in a discontinuity sufficient to violate the requirement that 2 inches of continuous vertical coverage be provided. A copy of an August 21, 1987, letter to Daihatsu Motor Co. which addresses this issue, is enclosed for your information.

  4. What is the length, in mm the pelvic area in H-PT in the FMVSS 201 regulations.

    The pelvic impact area is defined in 49 CFR Part 571.3. The dimensions given in that definition have not yet been converted from english to metric. The pelvic impact area is that area of the door or body panel adjacent to any outboard designated seating position which is bounded by horizontal planes 7 inches above and 4 inches below the seating reference point and vertical transverse planes 8 inches forward and 2 inches rearward of the seating reference point. Therefore, the location of the pelvic impact area is dependent on the location of the seating reference point within the vehicle.

    The seating reference point is defined in 49 CFR 571.3 as the unique design H-point, as specified in SAE J1100 (June 1984), which:

    1. Establishes the rearmost normal design driving or riding position of each designated seating position, which includes consideration of all modes of adjustment, horizontal, vertical, and tilt, in a vehicle;

    2. Has X, Y, and Z coordinates, as defined in SAE J1100 (June 1984), established relative to the designed vehicle structure;

    3. Simulates the position of the pivot center of the human torso and thigh;


    4. Is the reference point employed to position the two-dimensional drafting template with the 95th percentile leg described in SAE J826 (May 1987), or, if the drafting template with the 95th percentile leg cannot be positioned in the seating position, is located with the seat in its most rearward adjustment position.

    Once this H point is located, the pelvic impact area may be located on a door or body panel. As the pelvic impact zone extends eight inches forward of the H-Point and two inches rearward from the H-Point, the pelvic impact area is 10 inches long.

I hope that this information is helpful. If you have any questions, please contact Otto Matheke of my staff at (202) 366-5253.


John Womack

Acting Chief Counsel