Interpretation ID: aiam2987
Jr.
Director of Design
Cars & Concepts
Inc.
12500 E. Grand River
Brighton
MI 48116;
Dear Mr. Pare: This responds to your March 2, 1979, letter concerning the definitio of the vehicle sub-classification, 'convertible.' Your letter included several Figures of various vehicle designs and asked whether each would be considered a 'convertible' by the National Highway Traffic Safety Administration.; While our regulations do not include a formal definition o 'convertible', the agency has stated that it considers a convertible to be a vehicle whose 'A' pillar or windshield peripheral support is not joined with the 'B' pillar (or rear roof support rearward of the 'B' pillar position) by a fixed rigid structural member. Therefore, passenger cars equipped with a 'sun roof' or a 'Hurst hatch roof' do not qualify as convertibles, because they have a fixed, rigid structural member in the described location (April 21, 1976, letter of interpretation enclosed). This interpretation applies, moreover, whether the rigid structural member joining the 'A' and 'B' pillars is a hidden reinforcing component or whether the structural member is part of the exterior roof panel.; Given this interpretation, only the Fiat X-19 vehicle desig illustrated in your Figure 5 would qualify as a 'convertible.' Each vehicle design in your other illustrations (Figures 1, 2, 3, 4, 5, 6, 7, 8 and 9) include fixed, rigid structural components joining the 'A' and 'B' pillar sections of the vehicles and, therefore, would not be classified as convertibles. Likewise, the designs would not be considered 'open-body type vehicles' (49 CFR 571.3) for the same reason, the structural member, whether hidden or not, would be considered part of the vehicle top. Also, I would point out that the 'open-body vehicle' designation generally refers to multipurpose passenger vehicles such as 'Jeeps' or 'dune buggies.'; I hope this clarification is responsive to your inquiry. If you hav any further questions please contact Hugh Oates of my office (202-426-2992).; Sincerely, Frank Berndt, Acting Chief Counsel