Interpretation ID: NCC-230816-001 Antolin Sun Visor
May 17, 2024
Dr. Enrique Curiel Sanz
Passive Safety Manager – Engineering Shared Services
Grupo Antolin
Enrique.curiel@grupoantolin.com
Dr. Curiel Sanz,
This responds to your email to the National Highway Traffic Safety Administration (NHTSA) concerning the standards that sun visors must meet under the Federal Motor Vehicle Safety Standards (FMVSS). Your question concerns evaluation of sun visors, specifically how NHTSA determines if the sun visor is covered in an energy absorbing material. Please note that our answer below is based on our understanding of the specific information provided in your email.
Background
NHTSA is authorized by the National Traffic and Motor Vehicle Safety Act (Safety Act, 49 U.S.C. Chapter 301) to issue federal motor vehicle safety standards (FMVSS) that set performance requirements for new motor vehicles and new items of motor vehicle equipment. The Safety Act requires manufacturers to self-certify that their vehicles and equipment conform to all applicable FMVSS in effect on the date of manufacture. NHTSA also investigates safety-related defects.
In your July 19, 2023 message, you asked about the evaluation criteria for sun visors. Specifically, you asked whether sun visors are tested with a pendulum to determine if they are made of an energy absorbing material, and if so, which criteria are used to determine whether the sun visor passes or fails the test. On July 24, 2023, NHTSA responded to your message, indicating that the sun visor requirements in FMVSS No. 201 require that the visor be constructed of or covered with energy absorbing material and that each sun visor mounting present no rigid material edge radius of less than 3.2 mm that is statically contractable by a spherical 165 mm diameter head form. Thereafter, you requested clarification as to how a manufacturer may confirm that a visor’s material meets the definition of “energy-absorbing,” such as material composition or testing under impact conditions.
Discussion
As explained, under the Safety Act, each manufacturer of a motor vehicle or item of motor vehicle equipment is responsible for certifying that its products meet all applicable safety standards. Given
1 49 U.S.C. 30115.
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Dr. Enrique Curiel Sanz
this “self-certification” regime, NHTSA does not certify or approve motor vehicles or motor vehicle equipment for compliance with the FMVSS. Manufacturers may not certify a vehicle or item of motor vehicle equipment if, “in exercising reasonable care, [they have] reason to know the certificate is false or misleading in a material respect.”
2
FMVSS No. 201, “Occupant protection in interior impact,”3 establishes performance requirements designed to reduce the risk of injury in the event an occupant strikes the interior of a vehicle during a crash. Paragraph S5.4 of the standard requires that sun visors be “constructed of or covered with energy-absorbing material” and that the visor’s mounting must “present no rigid material edge radius of less than 3.2 mm that is statically contactable by a spherical 165 mm head form.” The purpose of this requirement is to reduce the injuries that occur when occupants strike the visor or visor mounting with their heads.
The standard does not further define “energy-absorbing.” Moreover, neither the standard nor NHTSA’s own test procedure4 provides a performance-based or material definition of energy-absorbing, or a test for measuring the energy-absorption capability of sun visor material. Further, the laboratory test procedure for assuring compliance with the standard requires only that the sun visor be made of an energy-absorbing material; no further guidance is provided. Therefore, the responsibility is with the manufacturer to self-certify that the material from which sun visors are constructed or with which they are covered is energy-absorbing to meet the requirements of this standard.
In so doing, please note that in addition to meeting the S5.4 requirements, S4.2 dictates that vehicles must also comply with the requirements of S6. S6.1.4.2 in turn requires that new vehicles meet the performance standards set forth in S7. Therefore, in addition to the requirement that sun visors be constructed of or covered in an energy absorbing material, manufacturers of sun visors must construct them in such a manner as to ensure compliance with the performance standard of S7 when installed in a vehicle. Compliance with S7 will ensure that the sun visors meet the performance standard, which is what NHTSA requires, along with ensuring that all components are free of safety defects.
I hope this information is helpful. If you have any further questions, please feel free to contact Terrence Sommers of my staff at the address above or at (202) 366-7577.
Sincerely,
Adam Raviv
Chief Counsel
2 Id.
3 Available at https://www.govinfo.gov/content/pkg/CFR-2022-title49-vol6/pdf/CFR-2022-title49-vol6-sec571-201.pdf (last accessed May 16, 2024).
4 Available at https://www.nhtsa.gov/sites/nhtsa.gov/files/documents/tp-201-02a_tag.pdf (last accessed May 16, 2024).
Dated: 5/17/24
Ref: Standard No. 201