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Interpretation ID: nht79-2.5

DATE: 04/23/79


TO: Studio Aguila


TEXT: This responds to your March 12, 1979, letter asking whether a sports car designed for use without doors must comply with Federal Motor Vehicle Safety Standard No. 214, Side Door Strength (49 CFR 571.214). The vehicle design discussed in your letter would apparently only have attachable doors for use in bad weather.

Since the test procedures in Safety Standard No. 214 require a loading device to be placed against the vehicle door, a passenger car having no doors could not practicably be tested. Therefore, a vehicle having doors that are designed to be easily attached to or removed from the vehicle are not required to comply with Safety Standard No. 214, if the vehicle is designed to be operated without the doors.


MARCH 12, 1979

Joseph J Levin Jr Chief Counsel Deartment of Transportation NATIONAL HIGHWAY AND TRAFFIC SAFETY ADMINSTRATION

Dear Mr. Levin,

Our office would like clarification from your Department on a point of ruling refering to USFMVSS 214.

We have a client, for whom we are developing a vehicle design aimed at introduction into the US market. This vehicle, being principally recreational in nature (In the sense of a sports car rather than a camper) is designed for use without doors.

Whilst this clearly is covered in clause S4 of VS206 we are concerned about VS214.

On the face of it one might say this vehicle need not comply with the standard VS214 as doors are not fitted except as draft excluders for use in any inclement weather. (Ref: VS206).

However, as we see it, although the rule VS214 states its purpose is to test door strength, the intent and partialy stated objective is to prevent injury to the occupants in a side collision situation. We feel therefore morally obliged to meet this aspect of the rules intent.

We would like your confirmation of the following points in this regard.

1/ Does the fact that the vehicle complies with VS206 Clause S4 (ie is Designed for use without doors) mean that we are not required to demonstrate compliance with VS-216?

2/ If the answer to the above is affirmative and we do have to show compliance with VS214 how should we locate the test device when we have no door?

3/ May we demonstrate compliance by placing the loading device at a height above the ground line with the vehicle loaded to its GVW which corresponds to the typical height at which the load device would be placed for the majority of the US vehicle population?

Our vehicle has extremely deep sills which are effectively very deep but rigidly integrated into the chassis structure, doors.

May we therefore locate the test device with reference to this sill provided that the height covered (See first para of Q3) indicates the strength at the point at which a side intrusion at an intersection collision is most likely to occur?

If we can have your confirmation of approval of proceedures outlined in 3, we will test to VS214 on those lines.

Otherwise we shall require a clear answer to Q1/.

We are looking forward to your reply at your earliest opportunity.