Interpretation ID: aiam3996
Executive Vice President and General Manager
Mazda (North America)
Inc.
24402 Sinacola Court
Farmington Hills
MI 48018;
Dear Mr. Miroyoshi: Thank you for your letter of July 2, 1985, requesting an interpretatio of Federal Motor Vehicle Safety Standard No. 201, *Occupant Protection in Interior Impact*. You specifically asked whether a design alternative you are considering for an interior storage compartment would have to meet the requirements of S3.3 of the standard. As explained below, we would consider your design to be an interior compartment door assembly and thus subject to the requirements of S3.3 of the standard.; You described your design as an interior surface with an integrate map/magazine compartment. Your proposed design consists of a compartment with a rigid exterior surface that remains open at a fixed width. You said that when a motorist wanted to stow a thicker package in the compartment, the opening could be expanded to a greater width. The drawing accompanying your letter shows that the exterior surface (i.e., the surface nearest to a vehicle occupant) is hinged, the movement of the hinged surface is restricted by a spring. It appears from your drawing that if the spring broke or otherwise became disengaged in a crash, the exterior surface of the compartment would swing open on its hinge and be struck by a vehicle occupant. Such an action is similar to what could happen with the conventional hinged glovebox or other doors in a vehicle. We would therefore consider your proposed design to be an interior compartment door assembly.; I hope this information is of assistance to you. If you have furthe questions, please let me know.; Sincerely, Jeffrey R. Miller, Chief Counsel