Interpretation ID: 86-4.43

TYPE: INTERPRETATION-NHTSA

DATE: 08/18/86

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Mr. William H. Spain

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of May 20, 1986, asking how our regulations would apply to a wooden steering wheel you manufacture. You explained that you use a standard steering wheel with a steel outer rim. The steel outer rim is then veneered with wood, which is covered with a protective finish. The finished wheel will then be use as an item of original equipment by a vehicle manufacturer. I hope the following discussion answers your question.

The agency has issued two Federal Motor Vehicle Safety Standards that set occupant crash protection performance requirements for vehicle steering systems, which includes the steering wheel. Those standards are Standard No. 203, Impact Protection for the Driver from the Steering System, and Standard No. 204, Steering Column Rearward Displacement. Those two standards do not regulate the types of material that may be used in the steering wheel, but instead set performance requirements that the steering systems must meet under certain test conditions. Therefore, a manufacturer may use any material in its steering wheel, as long as the steering system still complies with the performance requirements of Standard Nos. 203 and 204.

If you have any further questions, please let me know.

Sincerely,

NATIONAL MANAGEMENT, INC.

May 20, 1986

Erika Z. Jones, Chief Counsel National Highway Traffic Safety Administration

Dear Ms. Jones,

Confirming our telephone conversation of May 20, 1986 with your Mr. Steve Oesch, we have a tenative inquiry from a small manufacturer of automobiles for the purchase of wood steering wheels.

The steering wheels would be installed by the manufacturer as original equipment. We would use a standard steering wheel with a steel outer rim. The steel outer rim would be veneered with wood and then covered with protective coats of clear polyeutherene finish. There would be no modification to the steering wheel hub itself.

The manufacturer asked if there would be any problems with your office on this approach. I have discussed this briefly with your testing and engineering people and their first impression is that the material of which the rim is constructed is of no consequence so long as the steering assembly complies with the applicable regulations.

We would appreciate your taking the time to confirm whether or not we should anticipate any difficulties with your department using this approach.

Your department's time and courtesy are appreciated.

NATIONAL INDUSTRIES

William H. Spain