Interpretation ID: aiam1649
Manager
Emissions
Safety & Development
Volkswagen of America
Inc.
Englewood Cliffs
NJ 07632;
Dear Mr. Kennebeck: This responds to your October 17, 1974, request for an interpretatio of the term 'walk-in van-type vehicle' as it is used in S4.2.3 of Standard No. 208, *Occupant crash protection*.; This vehicle category is not defined in the standard or in 49 CF S571.3, *Definitions*. Review of its use in the rulemaking which resulted in S4.2.3 makes clear that it includes only a small category of vehicles with a distinctive configuration. Our preamble discussion in Notice No. 9 of Docket No. 69-7 (36 F.R. 4600, March 10, 1971) stated 'Review of the comments and the petitions for reconsideration leads to the conclusion that this type of vehicle [open-body type vehicles], along with convertibles, walk-in van-type vehicles. . . cannot be satisfactorily equipped with a complete passive protection system.'; International Harvester used the term 'walk-in van-type truck' in it comments to describe its 'Metro' delivery vehicle (Comment 69-7-9, December 2, 1970). It requested exclusion of this vehicle from barrier crash testing as too severe for vehicles 'mainly used in low-speed, city-delivery type operations' while maintaining the necessary walk-in feature. Modifications, it argued, would eliminate the walk-in feature and much of the utility of short, high-capacity, city delivery vehicles. It is our interpretation that the term 'walk-in van-type truck' only covers the 'step van' delivery vehicle of which the International Harvester 'Metro' is one example. If you have a question concerning the categorization of one of Volkswagen's vehicles, I suggest that you submit a description of the vehicle to us, on the basis of which we will give you a definitive answer.; Yours truly, Richard B. Dyson, Acting Chief Counsel