Interpretation ID: aiam3614
Nissan Motor Co.
Ltd.
Suite 707
1919 Pennsylvania Avenue
N.W.
Washington
DC 20037;
Dear Mr. Suzuki: This is in response to your September 23, 1982, letter regarding th applicability of Federal Motor Vehicle Safety Standard No. 118, *Power-Operated Window Systems*, to power sunroofs. The agency apparently has never previously addressed this question.; Standard 118 specifies requirements only for power-operated window an partition systems. A power sunroof would be considered neither a 'window' nor a 'partition,' and therefore would not be subject to the standard. Our standard was intended to apply to the typical power side windows and the power tailgate windows of station wagons. The reference to 'partitions' in the standard was adopted as part of the July 23, 1970, final rule establishing Standard 118 and was intended to assure that power-operated interior partitions, such as might be used in a taxi or a limousine, would comply.; Although Standard 118 does not apply to power sunroofs, we strongl recommend that safety precautions along the lines of those established in that standard be incorporated in power sunroof designs. It appears possible that the types of accidents which the standard was intended to prevent could also occur as a result of the unsupervised operation of power sunroofs.; If you have any further questions on this matter, please contact us. Sincerely, Frank Berndt, Chief Counsel