Interpretation ID: aiam3832
Executive Vice President
MMC Services
Inc.
3000 Town Center
Suite 1960
Southfield
MI 48075;
Dear Mr. Kano: This responds to your letter inquiring about the test specifications o Safety Standards 203 and 204 and the New Car Assessment Program. You specifically asked about the positioning of a tilting steering wheel for each of those tests. The answers to your questions are as follows.; Standard No. 203 incorporates by reference Society of Automotiv Engineers Recommended Practice J944, December 1965. SAE J944 provides that a steering wheel is to be mounted at the angle specified by the manufacturer's 'package drawing.' Therefore, a tilting steering wheel would be placed at the nominal design position set by the manufacturer.; Standard No. 204 does not specify the positioning of a tilt wheel. I Standard No. 204 compliance testing, our Office of Vehicle Safety Compliance positions adjustable steering columns and wheels at the midpoint of the tilt and telescope adjustments. In the case of your particular tilting steering wheel, there is no midpoint. Thus, we would test the vehicle with the steering wheel in the position which is closest to the geometric center of the steering column. Based on the sketch enclosed in your letter, it appears that tilt positions 2 and 3 of your wheel are at an equal distance from the geometric center of the steering column. Therefore, your tilt tilt (sic) steering wheel should be capable of complying when tested in either of those positions.; The New Car Assessment Program does not use the Standard No. 208 tes procedures, but instead uses its own set of test procedures. Those procedures specify that an adjustable steering wheel is to be positioned at the midpoint of its tilt adjustment. Since there is no midpoint for your wheel, the wheel would be set at the position closest to the geometric center of the steering column. As discussed above, the agency would use either position 2 or 3 for your tilt wheel.; If you have any further questions, please let me know. Sincerely, Frank Berndt, Chief Counsel