Interpretation ID: 1983-1.10

TYPE: INTERPRETATION-NHTSA

DATE: 01/28/83

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Mazda (North America) Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your November 15, 1982 letter regarding the applicability of certain requirements in Federal Motor Vehicle Safety Standard (FMVSS) 219, Windshield Zone Intrusion, to two proposed cowl designs.

FMVSS 219 provides that no part of a vehicle outside the occupant compartment, "except windshield molding and other components designed to be normally in contact with the windshield," may penetrate a specified protected zone template on the windshield during a vehicle test crash. In your letter, you present two possible vehicle designs in which the cowl would directly contact the windshield. In one design, the contact would occur across most of the width of the windshield, while in the other, the contact occurs only at the outside edges of the cowl.

Both designs appear to fall within the exception in the standard for components "designed to be normally in contact with the windshield," and therefore the cowl would be permitted to penetrate the protected zone template. Nevertheless, I should mention that your second design does raise some concerns. It is difficult to determine from the drawings enclosed with your letter the extent of the windshield-cowl contact in your second design. If this contact were for such a short distance that it would be apparent that the design was intended to circumvent FMVSS 219 by establishing only minimal contact, the agency would consider taking appropriate action to assure that the intent of the standard is carried out.

SINCERELY,

MAZDA (NORTH AMERICA), INC. Detroit Office

November 15, 1982

Frank Berndt Chief Counsel National Highway Traffic Safety Administration

RE: Interpretation of FMVSS 219, Windshield Zone Intrusion

Dear Mr. Berndt:

Mazda respectfully submits this letter to request an interpretation of the requirements (S5.) of FMVSS 219, Winshield Zone Intrusion. The requirement states, ". . . . .No part of the vehicle outside the occupant compartment, except windshield molding and other components designed to be normally in contact with the windshield, . . . . . . . . . . ."

Mazda is developing a new model in which the cowl, by design, contacts the lower portion of the windshield. There are two designs being considered, as shown in the attached sketches.

According to our interpretation of the standard, the cowl would be part of "other components designed to be normally in contact with the windshield".

We would appreciate your interpretation with regard to this matter at your earliest convenience.

Thank you.

H. Nakaya Manager

CASE I - Complete contact with windshield

Windshield

CASE II - Partial contact with windshield (contact at left and right side)

(Graphics omitted)