Interpretation ID: aiam3271
Manager
Automobile Division
Sleek-Craft Boats
P.O. Box 3563
Santa Fe Springs
CA 90670;
Dear Mr. Robbins: This responds to your recent letter requesting an interpretation o Safety Standard No. 214, *Side Door Strength*, as it would apply to a new sports car that your company intends to market. You state that the side doors of this vehicle design can meet the 'intermediate' and 'peak' crush resistance requirements of the standard but not the 'initial' crush resistance requirement because of an outer fiberglass veneer component of the door. You ask whether the vehicle can be exempt from this 'initial' requirement since the door can withstand the maximum forces required by the standard.; The answer to your question is no. Safety Standard No. 214 require doors to comply with all three stages of the crush resistance requirements and there is no provision for an averaging of the crush resistance abilities. Although inboard mounted structures may be effective in preventing intrusion if the door has a large cross section, with a correspondingly large distance between the protective structure and the inner panel, the standard reflects a determination by the agency that doors afford the greatest protection if the crush resistance elements are as close to the outer panel as possible. Additionally, the 'initial' crush resistance requirements are necessary to ensure that the entire door system is structurally sound. This is particularly important because of the risk of occupant ejection if door hinges and latches separated during an accident, allowing the door to fly open.; Although the relief you seek cannot be granted by interpretation o Safety Standard No. 214, there are provisions for temporary exemptions from Safety Standards or portions of safety standards under certain circumstances, such as economic hardship. I am enclosing a copy of the regulation governing temporary exemptions for your information (49 CFR Part 555). After reviewing this regulation, you may wish to petition the agency for a temporary exemption from the 'initial' crush resistance requirements of the standard. The regulation explains the procedures you must follow.; If you have any further questions, please contact Hugh Oates of m office at 202-426- 2992.; Sincerely, Frank Berndt, Chief Counsel