Interpretation ID: aiam4135
Nissan Research & Development
Inc.
P.O. Box 8650
Ann Arbor
MI 48104;
Dear Mr. Tanuma: Thank you for your letter of February 5, 1986 (ref. W-141-H) concerning the application of Standard No. 201, *Occupant Crash Protection in Interior Impact*, to an inside door 'pull-handle.' You explained that the pull-handle is made of unpadded plastic and does not have a hard inside frame. The drawing provided in your letter shows that the pull-handle is 7.44 inches (186 mm) long, 1.12 inches (28 mm) wide, and projects 1.09 inches (27 mm) from the side of the door. I hope that the following discussion answers your questions.; You first asked if the armrest requirements of S3.5 of the standar would apply to the pull-handle if it is located within the pelvic impact area of either the front or rear passenger door. In determining whether the requirements of S3.5 apply to the structure, the agency has looked at the design and location of the structure, to determine whether it is an armrest (see, for example, the agency's interpretation letter of September 21, 1983, to Mr. Suzuki of your company.). In this case, the pull-handle projects far enough from the side of the door so that it could be used to rest the arm. Further, if the pull-handle were located in the pelvic impact area, it is likely to be used to rest the arm. Thus, we would consider such a pull-handle located in the pelvic impact area to be an armrest which must meet the requirements of S3.5 of the standard.; You also asked if the pull-handle would have to meet the requirement of S3.5 of the standard if it were located outside of the pelvic impact area at the upper portion of the door. In a conversation with Mr. Oesch of my staff, Mr. Hayaski explained that the pull-handle would probably be located near the rearmost edge of the door. In this case, it appears that the pull-handle would be positioned above and to the rear of where occupants would normally be expected to rest their arms. Thus, we would not consider a pull-handle located in the upper portion of the door and near the door's rear edge to be an armrest.; If you have any further questions, please let me know. Sincerely, Erika Z. Jones, Chief Counsel