Interpretation ID: nht91-3.33

DATE: April 29, 1991

FROM: Takashi Odaira -- Chief Representative, Emission & Safety, Isuzu Technical Center of America, Inc.

TO: P.J. Rice -- Chief Counsel, NHTSA

COPYEE: Mr. Fukuhara -- ISZ-J, R56; Mr. Sakai -- ISZ-J, R56; Mr. Watanabe -- ITCA-Det.; ISZA -- Washington, D.C.

TITLE: Subject: Rear Seat Requirements - Side Impact (FMVSS 214)

ATTACHMT: Attached to letter dated 6-25-91 from Paul Jackson Rice to Takashi Odaira (A38; Std. 214)

TEXT:

The purpose of this letter is to request your agency's interpretation regarding the applicability of the rear seat requirements FMVSS 214, "Side door strength" (55 FR 45722) published on October 30, 1990, in the context of Isuzu 2-door Coupe.

The Standard specifies ". . . the rear seat requirements do not apply to passenger-cars which have rear seating areas that are so small that the SID dummy cannot be accommodated according to the specified positioning procedures."

The point of our questions is whether Isuzu 2-door Coupe qualifies for this exemption.

In this vehicle, when the SID dummy is seated at the rear outboard passenger position according to the specified positioning procedures, the dummy's head comes into contact with the roof and backlight glass which have steep slopes. To avoid the interference, in our test, the head was tilted forward as much as possible and, in addition, the upper torso was also tilted forward, away from the seat back. Only in this way, could we accommodate the dummy in the seating area without changing the specified orientation of the thorax midsagittal plane, or affecting the H-point. This condition is shown in photographs 1, 2, 3 and Figure 1 attached here.

This condition, however, obviously does not meet the positioning procedure of paragraphs S7.1.3(a) and (b), which provides, "The upper torso of the test dummy rests against the seat back." In Isuzu 2-door Coupe, the dummy's upper torso must be tilted away from the seat back while adjusting its head forward as the Agency says in the preamble to this Standard (55 FR 45737, first column).

Therefore, our interpretation is that said Coupe cannot "accommodate" the SID dummy and thus the rear seat requirements are not applicable to it.

We would appreciate receiving your view regarding this interpretation and understanding. Your prompt response would be most helpful.

Attachments

Figure 1 -- SID dummy accommodation - Isuzu 2-door coupe; (text and graphics omitted);

Photograph 1 -- SID dummy accommodation - Isuzu 2-door coupe; (graphics omitted);

Photograph 2 -- SID dummy accommodation - Isuzu 2-door coupe; (graphics omitted);

Photograph -- 3 SID dummy accommodation - Isuzu 2-door coupe; (graphics omitted)