Interpretation ID: 86-1.14

TYPE: INTERPRETATION-NHTSA

DATE: 01/31/86

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Mr. Russ L. Bomhoff

TITLE: FMVSS INTERPRETATION

TEXT:

January 31, 1986 Mr. Russ L. Bomhoff Special Projects Director Precision Pattern Inc. 1643 S. Maize Road Wichita, Kansas 67209 Dear Mr. Bomhoff: Thank you for your letter of October 30, 1985, asking about the effect of our regulations on several components you wish to install in the interior of a passenger car. I hope the following discussion answers your questions. All new vehicles manufactured for sale in the United States must be certified by their manufacturer as complying with the Federal motor vehicle safety standards. If you are installing the components described in your letter in a new vehicle prior to its first sale to a consumer, then you would be considered a vehicle alterer. Under our certification regulation (49 CFR Part 567), a vehicle alterer must certify that the vehicle as altered continues to comply with all applicable Federal motor vehicle safety standards. Since you are modifying the interior of the passenger car, you must ensure that the vehicle will still comply with Standard No. 201, Occupant Protection in Interior Impact, a copy of which is enclosed. If you are making these alterations to a used vehicle, then you, as a commercial business, would be covered by section 108(a)(2)(A) of the National Traffic and Motor Vehicle Safety Act. That section prohibits manufacturers, dealers, distributors, and motor vehicle repair shops from knowingly rendering inoperative any element of design installed on a vehicle in compliance with Federal safety standards. Thus, in installing the components you described, you cannot render inoperative the vehicle's compliance with Standard No. 201 or any of our other standards. The potential effect of Standard No. 201 on each of the components you asked about is discussed below. Front and rear cooler consoles. S3.1 of the standard sets performance requirements for the instrument panel. S3.1.1(a) of the standard specifically provides that the instrument panel requirements do not apply to console assemblies. We would consider both the front and rear seat coolers to be console assemblies and thus exempt from the requirements of S3.1. S3.3 of the standard requires interior compartment door assemblies located in an instrument panel, a console assembly, a seat back, or a side panel adjacent to a designated seating position to remain closed under certain test conditions. The purpose of the requirement is to prevent a door from flying open and striking an occupant in a crash. The doors in the front and rear consoles would have to meet this requirement. Seat back fold-down tables. S3.2 of the standard sets performance requirements to limit injuries caused when rear seat occupants strike the seat backs in front of them. You would have to ensure that the seat backs would still comply with S3.2 when the fold-down tables are installed. The fold-down tables mounted in the seat back and the door do not have to meet the requirement in S3.3 for interior compartment doors. However, since both those items are hinged surfaces which could fly open in a crash and pose a hazard to an occupant in a crash, we urge you to ensure that the tables will be adequately secured in a crash. S3.5 of the standard sets requirements for armrests. You would have to ensure that the vehicle will still comply with S3.5 when the fold-down table is installed in the door. TV/VCR Cabinet There are no requirements that apply to the TV/VCR cabinet. If you have any further questions, please let me know. Sincerely, Original Signed By Erika Z. Jones Chief Counsel