Interpretation ID: aiam2910
Director
Governmental Relations
Saab-Scania of America
Inc.
Saab Drive
P.O. Box 697
Orange
Connecticut 06477;
Dear Mr. Millet: This is in response to your letter of 25 October 1978 concerning th requirements of S3.3 of Standard No. 201 as it applies to the instrument panel compartment door in the Saab 900. Your specific concern is the portion of S3.3 that provides, 'Additionally, any interior compartment door located in an instrument panel or seat back shall remain closed when the instrument panel or seat back is tested in accordance with S3.1 and S3.2.'; According to your letter, the hinges on the Saab 900 instrument pane compartment door are designed to deform to keep the compartment door closed if deformation resulting from the head impact requirements of S3.1 is great enough to open the compartment latch.; If the instrument panel compartment door remains closed during the hea impact tests of S3.1, the vehicle complies with that aspect of the requirements of S3.3 of Standard No. 201. The standard does not specify that the latch mechanism remain closed, only that the door 'shall remain closed.'; This interpretation should not be construed as an approval of Saab' instrument panel compartment door hinge system. Federal motor vehicle Safety standards are written primarily in terms of performance requirements which must be met in specified test, and a manufacturer is free to use any design it wishes to meet those performance requirements. Thus, this agency does not grant approval of specific systems or components in the vehicle. The manufacturer must exercise due care to assure that its vehicles comply with all applicable safety standards.; Please let me know if you have any further questions. Sincerely, Joseph J. Levin, Jr., Chief Counsel