Interpretation ID: aiam2265
Nissan Motor Co.
Ltd.
560 Sylvan Avenue
Englewood Cliffs
NJ 07632;
Dear Mr. Suzuki: This responds to your March 15, 1976, question whether a passenger ca is considered a convertible for purposes of compliance with motor vehicle safety standards if its roof includes a 'sun roof' or has two removable sections fitted into the roof over the dashboard front designated seating positions in such a fashion that they do not join each other (Hurst Hatch Roof). You also request confirmation that convertibles are excluded from the requirements of Standard NO. 216, *Roof Crush Resistance*, and are required to meet S4.1.2.3.2 of Standard No. 208, *Occupant Crash Protection*.; The answer to your first question is no. The National Highway Traffi Safety Administration considers a convertible to be a vehicle whose 'A' pillar or windshield peripheral support is not joined with the 'B' pillar (or rear roof support rearward of the 'B' pillar position) by a fixed, rigid structural member. Passenger cars equipped with a 'sun roof' or a 'Hurst Hatch Roof' do not qualify as convertibles, because they have a fixed, rigid structural member in the described location.; With regard to your other question, passenger cars manufactured fro September 1, 1973, to August 31, 1976, inclusive, are required to meet one of three options specified in Standard No. 208. If a manufacturer chooses to meet the third option listed (S4.1.2.3), separate requirements are specified for convertibles in S4.1.2.3.2. Convertibles are excluded form Standard No. 216, although a manufacturer may choose to meet the standard in place of certain requirements of Standard No. 208 that are not presently mandatory.; Yours truly, Stephen Wood, Assistant Chief Counsel