Interpretation ID: nht87-2.73

TYPE: INTERPRETATION-NHTSA

DATE: 08/20/87

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Karl-Heinz Faber

TITLE: FMVSS INTERPRETATION

TEXT: Karl-Heinz Faber Vice President Product Compliance and Service Mercedes-Benz of North America, Inc. P.O. Box 350 Montvale, NJ 07645

Dear Mr. Faber:

Thank you for your letter of April 16, 1987, concerning the requirements of Standard No. 208, Occupant Crash Protection. In particular, you asked for an interpretation of the requirements of @4.5.1 of the standard. I hope that the following discussion an swers your question.

@4.5.1 of Standard No. 208 provides that each vehicle with a crash deployed occupant protection system must have a label setting out a manufacturer's recommended schedule for the maintenance or replacement needed to keep the performance of the occupant p rotection system at the level required by the standard. @4.5.1 further provides that "the label shall be permanently affixed to the vehicle within the passenger compartment." You explained that at the present time, you placed the label for your air bag s ystem on the glove box door. You further explained that you placed all other important safety-related information, such as the certification label and tire information placard, on the latch post for the driver's door.

You stated that you want to relocate the air bag label from the glove box door to the latch post on the driver's side. You explained that one of the benefits of the new location is that it will establish a common location for the operator to quickly find important information. You said that the new location should remind vehicle operators of the replacement schedule since the tire pressure placard, which is routinely reviewed by the vehicle operator, is in the same location. Finally, you noted that deal ership service personnel will be alerted to the replacement schedule since "it is common practice for Service Writers to copy down the VIN from the certification label on the driver door latch post."

NHTSA agrees that a label placed on the driver's latch post would meet the requirements of @4. S. 1. The purpose of the location requirement is to place the replacement and maintenance schedule in a location that can be easily observed by the vehicle own er. Thus, the standard requires the label to be within the occupant compartment of the vehicle. The agency considers a label placed on thy latch post, which is inside the exterior surface of the vehicle and in a part of the physical structure that consti tutes occupant compartment, as meeting the location requirement. As you pointed out in your letter, the latch post is already used as a location for other important safety-related information about the vehicle.

If you have any further questions on this standard or need additional information, please let me know.

Sincerely,

Erika Z. Jones Chief Counsel

April 16, 1987

Ms. Erika Z. Jones, Chief Counsel Department of Transportation National Highway Traffic Safety Administration 400 Seventh Street N.W. Washington, D.C. 20590

Subject: Request for Interpretation Concerning FMVSS-208 Dear Ms. Jones:

Mercedes-Benz of North America, Inc. requests an interpretation of FMVSS-208 "Occupant Crash Protection in Passenger Cars, Multipurpose Passenger Vehicles, Trucks, and Buses". Paragraph @4.5.1 Labeling and Driver's Manual Information provides that, "The (crash deployed occupant protection system maintenance or replacement) label shall be permanently affixed to the vehicle within the passenger compartment ..." (emphasis added)

Our request for interpretation concerns the phrase "within the passenger compartment". Currently, our replacement label for the airbag system is contained on the glove box door. At the same time, all other critical vehicle information, such as the "certi fication label" and "tire information placard", are placed on the driver door latch post.

We intend to relocate our airbag replacement label specified by FMVSS-208 to the same driver door latch post area from the glove box door. This relocation will result in:

1. A common location established on the vehicle for the operator to more quickly find important information.

2. Vehicle operators being more often reminded to take notice of the replacement label since the tire pressure placard is also in this location and routinely reviewed.

Ms. Erika Jones page 2 Request for Interpretation Concerning FMVSS-208

3. Dealership service personnel will be more quickly alerted to vehicles at or near their replacement date since it is common practice for Service Writers to copy down the VIN from the certification label on the driver door latch post.

We regard the driver door latch post area where the label will be placed as within the confines of the passenger compartment as required by the regulation. The label will be placed on the passenger compartment side of the outer door seal.

We would appreciate your confirmation of our location interpretation and thank you in advance for your response.

Sincerely,