Interpretation ID: 7200
Attorney at Law
325 Exterior Street
Bronx, NY 10451
Dear Mr. Friedkin:
This responds to your follow-up letter to the agency requesting that the agency provide "the applicable 1986 standard for convertible passenger cars." In an earlier letter, you had asked about our regulations with respect to converting a vehicle from a hardtop to a convertible. I am pleased to have this opportunity to respond to your inquiry.
To begin, there is no single standard applicable to convertible passenger cars, or any other motor vehicles. Instead, the National Highway Traffic Safety Administration (NHTSA) is authorized under the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1381 et seq.; Safety Act) to issue safety standards applicable to new motor vehicles and items of motor vehicle equipment. We have exercised this authority to establish many standards that apply to passenger cars, including convertible passenger cars. These standards, which are collectively called the Federal motor vehicle safety standards, are set forth in 49 CFR Part 571. They cover many different vehicle systems, including controls and displays, vehicle lighting, braking, occupant crash protection, and fuel system integrity.
As you review the safety standards in Part 571 to see which aspects of performance are of particular interest to you, you will see that the standards are generally identical for passenger cars and convertible passenger cars. There are some differences, however, including the permissible location for the center high mounted stop lamp (S5.3.1.8 of Standard No. 108, Lamps, Reflective Devices and Associated Equipment) and the inapplicability of the roof crush standard to convertibles (S3 of Standard No. 216, Roof Crush Resistance). Additionally, Standard No. 208, Occupant Crash Protection, required the front outboard seating positions of 1986 passenger cars that were not equipped with automatic crash protection (either air bags or automatic belts) to be equipped with a lap/shoulder belt and all other seating positions to be equipped with either a lap belt or a lap/shoulder belt (S4.1.2.3.1 of Standard No. 208). However, convertible passenger cars were permitted to offer either a lap belt or a lap/shoulder belt at every designated seating position, including the front outboard positions (S4.1.2.3.2 of Standard No. 208.
I hope this information is helpful. If you have any further questions about NHTSA's safety standards, please feel free to contact Marvin Shaw of my staff at this address or by telephone at (202) 366-2992.
Sincerely,
Paul Jackson Rice Chief Counsel
Ref:108#208#216 d:6/l5/92