Interpretation ID: aiam4178
P.E.
Manager
Regulatory Affairs
Volvo Cars of North America
Rockleigh
NJ 07647;
Dear Mr. Shapiro: Thank you for your letter of May 5, 1986, requesting an interpretatio of how the requirements of Standard No. 212, *Windshield Retention*, apply to a passenger car that is equipped with a driver-only air bag system. As explained below, such a vehicle must retain not less than 50 percent of the windshield periphery after being tested in accordance with Standard No. 212.; Standard No. 212 sets different windshield retention requirements for vehicle depending on whether it is equipped with passive or manual restraints. S5.1 of the standard provides that vehicles equipped with passive restraints must retain not less than 50 percent of the windshield periphery after crash testing. S5.2 of the standard provides that vehicle (sic) that are not equipped with passive restraints must retain not less than 75 percent of the windshield periphery.; You noted that S4.1.3.4(b) of Standard No. 208 provides that, fo purpose of calculating the number of passive restraint-equipped cars during the phase-in of passive restraints, a car with a driver-only, non-belt passive restraint will be counted as a vehicle complying with the passive restraint requirements of S4.1.2.1(a). Such a driver-only system can have a manual safety belt installed at the right front passenger position. You said that Volvo considers a vehicle with a driver-only, non-belt system to be a passive restraint vehicle and thus subject to the 50 percent windshield retention requirement of S5.1 (sic); As discussed in a July 5, 1977, Federal Register notice (42 FR 34288) one of the reasons the agency adopted the 50 percent retention requirement for passive restraint-equipped vehicles was because there could be contact between an air bag system and the windshield. In addition, there could be incidental contact between an air bag- restrained test dummy and the windshield. Because the same air bag-to-windshield and dummy-to-windshield contact is possible in a vehicle equipped with a driver-only air bag system, the agency believes that it is appropriate to apply the 50 percent retention requirement to a driver-only air bag system.; If you have any further questions, please let me know. Sincerely, Erika Z. Jones, Chief Counsel