Interpretation ID: nht73-4.23

DATE: 05/30/73

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Volvo of America Corp.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of May 8, 1973, concerning the intent of Section S4.7 of the amendment of Motor Vehicle Safety Standard No. 201 proposed by the notice of September 25, 1970. Although we have recently issued a notice advising the public that we intend to issue a further proposal on this subject before adopting a final rule, we can provide a brief explanation of the intent of Section S4.7.

The principal portions of the "A" and "B" pillars to which S4.7 was directed, are those portions lying above the low line of the vehicle's window. However, the breadth of S4.7 is such that it would also include all contactable areas of the pillars lying below the window line.

You will have further opportunity to comment on the use of force distributing materials and response to the rulemaking of Standard 201.

Yours truly,

Volvo of America Corporation

May 8, 1973

Lawrence Schneider, Esq. General Counsel National Highway Traffic Safety Administration

Re: Request for clarification of Federal Motor Vehicle Safety Standard No. 201 49 CFR Part 571

Volvo of America Corporation hereby requests clarification of Federal Motor Vehicle Safety Standard No. 201 as it relates to the "A" and "B" pillars of a vehicle.

It is our understanding that the standard as currently in effect does not specify requirements for the "A" and "B" pillars. However, Docket No. 2-1, Notice 2 as published in the September 25, 1970 Federal Register (page 14936) proposed an upgrading of Standard 201 which would have required force-distributing material on these surfaces. Although this proposed amendment has never been adopted, it is the best indication that we have to date of N.H.T.S.A.'s thinking in regard to requirements for the "A" and "B" pillars and we are using the information for planning purposes.

It is in regard to paragraph S4.7. of Docket No. 2-1; Notice 3 that we require clarification as follows:

S4.7. Pillars.

(quote)

The contactable surface of each "A" and "B" pillar, with the doors and windows closed, shall -

(a) Be covered with force-distributing material having a thickness of at least 0.50 inch; and

(b) With the force-distributing material removed, have no rigid contactable edge with a radius less than 0.50 inch.

2

Paragraph S3. "Definitions" of Docket No. 2-1; Notice 3 defines the term "contactable" as follows:

"Contactable" means able to be contacted from any direction by a 6.5-inch diameter rigid head form under a 90-pound static force.

Question:

Is it N.H.T.S.A's intention in paragraph S4.7. of the proposal to require that the "A" and "B" pillars be covered with force-distributing material for their entire length, i.e. from the roof to the floor, providing that the entire length is "contactable" as defined in paragraph S3.?

Your consideration of and a reply to our inquiry is requested as soon as practical. Thank you in advance for your consideration.

Very truly yours,

Donald W. Taylor Engineering Liason Representative

cc: D. Jarman L. Larsen G. Nield C. Simerlein E. Skarin