Interpretation ID: aiam3592
Executive Vice President
MMC Services Inc.
3000 Town Center
Suite 1960
Southfield
MI 48075;
Dear Mr. Kano: This responds to your letter of July 15, 1982, concerning th application of Standard No. 201, *Occupant Protection in Interior Impact*, to a passenger 'assist grip' provided in your vehicles. You asked whether the instrument panel impact test of the standard must be conducted both with and without the passenger grip mounted on the instrument panel.; The head impact test should be conducted with the passenger 'assis grip' mounted in place. It should not be necessary to test the panel with the grip removed. Section 5.3.1 of the Standard provides that if an area of the instrument panel is within the head impact zone, it must meet the performance requirements of the standard. In using the term 'instrument panel', the agency intended to include the basic panel and any integral design features of the panel. Your engineering drawing shows that the grip is solidly mounted on top of the panel as an integral part. You state that the grip is a standard design feature on all the vehicles you intend to manufacture. Because the grip is a standard design feature which is securely affixed to the instrument panel, the agency considers it an integral part of the panel. Thus, the performance requirements of the standard would be applicable with the grip mounted in place.; If you have any further questions, please let me know. Sincerely, Frank Berndt, Chief Counsel