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Interpretation ID: aiam3524

Mr. Brian Gill, Manager, Certification Department, American Honda Motor Co., Inc., P.O. Box 50, Gardena, CA 90247; Mr. Brian Gill
Manager
Certification Department
American Honda Motor Co.
Inc.
P.O. Box 50
Gardena
CA 90247;

Dear Mr. Gill: This is in reply to your letter of December 11, 1981, asking fo confirmation of your interpretation of paragraph S5.2.5 of Motor Vehicle Safety Standard No. 123, *Motorcycle Controls and Displays*.; Paragraph S5.2.5 requires that 'Each footrest for a passenger othe than an operator shall fold rearward and upward when not in use.' Honda would like to use a 'footboard' instead of a 'footrest'. In folding, the footboard folds upward in a clockwise manner and rearward and Honda believes that this meets Standard No. 123. We consider that the purpose of S5.2.5 is to prevent accidents caused by rigid footrests contacting the ground in a banking turn. The outer edge of the footboard in plan view lies inboard of wider parts of the vehicle such as the engine guard pipe and side bumper. This means that these portions of the motorcycle would contact the ground in an extreme banking turn before the proposed footboard.; The standard specifies no direction of upward motion of the footrest We believe your design complies with the intent of Standard No. 123.; Sincerely, Frank Berndt, Chief Counsel