Interpretation ID: aiam3062
Director of Legal Research
The Institute For Safety Analysis
6400 Goldsboro Road
Bethesda
Maryland 20034;
Dear Ms. Lindsey: This responds to your letter of July 9, 1979, concerning Federal Moto Vehicle SAfety Standard No. 201, *Occupant Protection in Interior Impacts*.; Your research concerning the history of the standard is correct. Th first notice of proposed rule making on Standard No. 201 (31 F.R. 15212, December 3, 1966) proposed a definition and requirements for the 'unrestrained child impact area.' When the standard was originally issue in final form (32 FR 2408, February 3, 1967), the unrestrained child impact area definition and requirements were deleted. In the same issue of the *Federal Register*, the agency issued an advance notice of proposed rulemaking stating that it intended to develop requirements to reduce impact hazards for unrestrained children (32 FR 2417). Although the agency did not subsequently publish any additional notices on Standard No. 201 specifically developed for the unrestrained child, the agency continued work on Standard No. 208, *Occupant Crash Protection*, and developed Standard No. 213, *Child Seating Systems*, both of which provide improved protection for children riding in motor vehicles.; The agency is currently studying the potential benefits of built-i interior padding, child restraint devices and other means of making the vehicle rear seat a safe environment for child transportation. This work may provide the basis for future rulemaking.; You are also correct that there were administrative law hearings hel on Standard No. 201. The record of those hearings, which were held May 22 and 23, 1967, in Detroit, Michigan, and may 24 and 25, 1967, in Washington, D.C., can be found in Docket 1, microfilm roll number 2. Please contact Ms. Hardee (426-2768) of the agency's docket section to make arrangements to view this material.; I hope this information will be of assistance. If you have an additional questions, please let me know.; Sincerely, Frank Berndt, Chief Counsel