Interpretation ID: nht87-1.94

TYPE: INTERPRETATION-NHTSA

DATE: 06/04/87

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Ching-Hsien Huang

TITLE: FMVSS INTERPRETATION

TEXT: Ching-Hsien Huang Branch Chief Structural Analysis Department Yue Loong Motor Engineering Center P.O. Box 510 Taoyuan, Taiwan 33099 Republic of China

Dear Mr. Huang:

Thank you for your letter of May 4, 1987, asking several questions about Standard No. 210, Roof Crush Resistance, and Standard No. 208, Occupant Crash Protection. You asked whether Standard No. 216 is still in effect. The answer is yes.

You also asked whether Standard No. 216 can be substituted for the rollover test contained in the first, second, or third option of Standard No. 208. - The answer is that compliance with the roof crush resistance requirements of Standard No. 216 cannot b e substituted for compliance with the rollover test of Standard No. 208.

I would like to clarify the applicability of the rollover test requirement of Standard No. 208 for you. The only rollover test contained in Standard No. 208 is found in 54.1.2.1 of the standard. A vehicle is subject to the test only if the vehicle's manu facturer chooses to meet it instead of an alternative requirement. 54.1. 2. l(a)- provides that a manufacturer has to meet the dynamic occupant protection requirements by automatic means in a frontal/angular crash test. In addition, a manufacturer must m eet 54.1.2.1(c). 54.1.2.1 (c ) provides a manufacturer with two options. A manufacturer can either meet the requirements of 54.1.2.1 (c)(l) and provide occupant crash protection by automatic means in a literal crash test and a rollover crash test or a ma nufacturer can meet the requirements of 54. 1. 2.1 (c) ( 2) and provide a manual lap or a manual lap/shoulder below at each front designated seating position. If a manufacturer chooses to meet 54.1.2.1 (c) ( 2), the vehicle must comply with 54.1.2.1(s) a nd provide occupant crash protection by automatic means in a frontal/angular test with the manual safety belt unfastened. In addition, the vehicle must provide occupant crash protection by automatic means in a frontal/angular test with the manual safety belt fastened.

I hope this answers your questions, if you need further information please let me know.

Sincerely,

Erika Z. Jones Chief Counsel

ERIKA Z. JONES CHIEF COUNSEL U.S. DEPARTMENT OF TRANSPORTATION NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION MAY 4, 1987

DEAR SIR,

WE ARE THE ENGINEERING CENTER OF YUE LOONG MOTOR COMPANY IN TAIWAN. PLEASE REPLY THE FOLLOWING QUESTIONS AS SOON AS POSSIBLE. (1) HAD STANDARD NO. 216, ROOF CRUSH RESISTANCE--PASSENGER CARS, BEEN REVOKED AFTER AUGUST 15, 1977)

(2) IF THE ANSWER OF (1) IS NO, CAN STANDARD NO. 216 BE A SUBSTITUTED FOR THE ROLLOVER TEST REQUIREMENT IN THE FIRST, SECOND, OR THIRD OPTION OF STANDARD NO. 208, OCCUPANT CRASH PROTECTION, NOWADAYS?

YOUR HELP WILL BE GREATLY APPRECIATED.

SINCERELY YOURS,

CHING-HSIEN HUANG BRANCH CHIEF STRUCTURAL ANALYSIS DEPT.