Interpretation ID: aiam3593
Nissan Motor Co.
Ltd.
Suite 707
1919 Pennsylvania Avenue
N.W.
Washington
DC 20037;
Dear Mr. Suzuki: This is to follow-up on your conversation with Stephen Oesch of m staff concerning the armrest requirement of Standard No. 201, *Occupant Protection in Interior Impact*. Your specific question concerned the application of section 5.3.1(c) of the standard to an armrest attached to a door. The inboard side of the armrest consists of two vertical surfaces, an upper one and a lower one. The upper surface extends 3 mm closer to the center of the vehicle than does the lower surface. You stated that the two surfaces when viewed in side elevation, *i.e.*, from the vantage point of the door latch or door hinges, together provide more than 2 inches of vertical height within the pelvic impact area. You also asked if section 5.3.1(c) set any limits on the material used for armrests.; Section 5.3.1(c) of the standard provides that: >>>Along not less than 2 continuous inches of its length, the armres shall, when measured vertically in side elevation, provide at least 2 inches of coverage within the pelvic impact area.<<<; Section 5.3.1(c) does not set any radius of curvature or heigh limitation on armrest surfaces. The only requirement is that the armrest provides at least 2 inches of coverage within the pelvic impact area. Section 5.3.1(c) also does not specify any limits on the materials that may be used in an armrest. Obviously, such surfaces must be designed carefully to ensure that the armrest does not concentrate potentially harmful forces on an occupant striking the armrest.; If you have any further questions please let me know. Sincerely, Frank Berndt, Chief Counsel