Interpretation ID: nht91-6.44

DATE: October 30, 1991

FROM: Jeff Ruff -- Director of Fleet/Government Sales, The Braun Corporation

TO: Office of the Chief Counsel, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 2/14/92 from Paul Jackson Rice to Jeff Ruff (A39; Std. 208)

TEXT:

I am writing to you in reference to FMVSS 208 and how it applies to the physically challenged. As a major supplier of equipment to the handicap industry, I offer the following concern:

It is our interpretation of FMVSS 208 and feed back from the OEM automakers that has prompted this letter. That interpretation and feedback tell us that the support brace between the "B" pillars and forward cannot technically be removed. If removed, the OEM automakers will not certify compliance with 208.

Unfortunately, the removal of this brace is imperative to the needs of the physically challenged and their ability to drive. As you can see in the pictures enclosed, if the support brace is left unaltered an individual with a high vertebrae injury would not be able to transfer to the driver's seat. (The original roof line is noted in marker.) Thus, the transportation of the physically challenged would be restricted to those without high vertebrae injuries and/or short people.

Please reconsider this ruling, or advise us as to how our industry can adapt to this requirement. I am familiar with the special revision concerning handicap seating dated 3-'86, page 33,181. Is it possible that a similar revision could be attached to FMVSS 208, or does that revision already apply to this situation?

Your immediate response to this matter will be greatly appreciated.