Interpretation ID: aiam4318
Branch Chief
Structural Analysis Department
Yue Loong Motor Engineering Center
P. O. Box 510
Taoyuan
Taiwan 33099
Republic of China;
Dear Mr. Huang: Thank you for your letter of May 4, 1987, asking several question about Standard No. 216, *Roof Crush Resistance, and Standard No. 208, *Occupant Crash Protection*. You asked whether Standard No. 216 is still in effect. The answer is yes.; You also asked whether Standard No. 216 can be substituted for th rollover test contained in the 'first, second, or third option of Standard No. 208.' The answer is that compliance with the roof crush resistance requirements of Standard No. 216 cannot be substituted for compliance with the rollover test of Standard No. 208.; I would like to clarify the applicability of the rollover tes requirement of Standard No. 208 for you. The only rollover test contained in Standard No. 208 is found in S4.1.2.1 of the standard. A vehicle is subject to the test only if the vehicle's manufacturer chooses to meet it instead of an alternative requirement. S4.1.2.1(a) provides that a manufacturer has to meet the dynamic occupant protection requirements by automatic means in a frontal/angular crash test. In addition, a manufacturer must meet S4.1.2.1(c). S4.1.2.1(c) provides a manufacturer with two options. A manufacturer can either meet the requirements of S4.1.2.1(c)(1) and provide occupant crash protection by automatic means in a lateral crash test and a rollover crash test or a manufacturer can meet the requirements of S4.1.2.1(c)(2) and provide a manual lap or a manual/shoulder belt at each front designated seating position. If a manufacturer chooses to meet S4.1.2.1(c)(2), the vehicle must comply with S4.1.2.1(a) and provide occupant crash protection by automatic means in frontal/angular test with the manual safety belt *unfastened*. In addition, the vehicle must provide occupant crash protection by automatic means in a frontal/angular test with the manual safety belt *fastened*.; I hope this answers your questions, if you need further informatio please let me know.; Sincerely, Erika Z. Jones, Chief Counsel