Interpretation ID: 1982-2.35

DATE: 08/10/82

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: MMC Services Inc.

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. Masakatsu Kano 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 the 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 "assist 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 engineering drawing shows that the grip is solidly mounted on top of the panel as an integral part. You stated 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,

Original Signed By Frank Berndt Chief Counsel

Mr. Frank A. Berndt, Chief Counsel National Highway Traffic Safety Administration U.S. Department of Transportation 400 Seventh Street, S.W. Room 5219 Washington, D.C. 20590

Dear Mr. Berndt:

MMC Services, Inc. on behalf of Mitsubishi Motor Corporation, we would like to have your confirmation of an interpretation we believe to be appropriate regarding the test procedure used in MVSS 201, Occupant Protection in Interior Impact.

Standard 201 requires that areas of the vehicle instrument panel which are within a specifically defined head impact area, be impacted by a 6.5 inch diameter head form. The test impact conditions are specified, as are the performance criteria which must be met. There is, however, no absolute definition of instrument panel--this is the area in which we feel an interpretation would be helpful.

On one of our multipurpose passenger vehicles, we provide a passenger assist grip, mounted on top of, and as part of, the instrument panel. We enclosed a picture showing this passenger assist grip. The grip is solidly mounted to the instrument panel, as shown by Section M-M on the enclosed engineering assembly drawing; and does fall within the MVSS 201 head impact area. The passenger assist grip is standard equipment on all models of this vehicle type.

Since all models will be manufactured with this passenger assist grip, we feel it is appropriate to conduct MVSS 201 certification test with the grip installed, and that it is not necessary to duplicate such tests on the instrument panel with the assist grip removed. We would very much appreciate your confirmation that this is an appropriate interpretation.

Because of the fact that we are working very hard to bring this vehicle model to the U.S. market as soon as possible, we would appreciate it very much if you could expedite your handling of this request to whatever extent possible. Thank you very much for your kind assistance in this regard.

Very truly yours,

Masakatsu Kano Executive Vice-President MMC Services, Inc.