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Interpretation ID: nht78-1.27

DATE: 06/15/78

FROM: AUTHOR UNAVAILABLE; J. J. Levin, Jr.; NHTSA

TO: Minnesota Claims Services

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your inquiry concerning the steering wheel system on a 1972 Plymouth Cricket. You ask whether Federal safety standards permitted non-collapsible steering columns on that vehicle model, whether the steering columns met all safety standards, and whether the vehicle manufacturer was exempted from Federal safety standards on the 1972 Plymouth Cricket because of hardship.

Federal Motor Vehicle Safety Standard No. 203, Impact Protection for the Driver from the Steering Control System (49 CFR 571.203), became effective for all passenger cars manufactured on or after January 1, 1968. Therefore, a 1972 Plymouth Cricket had to meet the performance requirements specified in that standard. I am enclosing a copy of Standard No. 203 for your information, and you should note that the standard does not specifically require "collapsible" loads that can be imparted by the steering column during a dynamic impact test.

Under Federal motor vehicle safety regulations, manufacturers are required to determine for themselves that their vehicles are in compliance and to certify the vehicles as being in compliance. The National Highway Traffic Safety Administration only conducts compliance tests on a "spot-check" basis for purposes of enforcement. Therefore, I cannot tell you whether the particular Plymouth with which you are interested was in fact in compliance with all safety standards. I can tell you that the agency has not made any determinations that the 1972 Plymouth Crickets failed to comply with Safety Standard No. 203.

Regarding your final question, no exemption from Standard No. 203 was granted for the 1972 Plymouth Cricket.

Please contact this office if you have any further questions.

SINCERELY,

April 4, 1978

Wayne C. Parsil Minnesota Claims Services

Dear Mr. Parsil:

This is in response to your March 29 letter regarding your investigation of an automobile accident involving a 1972 Plymouth Cricket, Serial Number 4C1L2R213949.

Your letter has been forwarded to the Associate Administrator for Enforcement, National Highway Traffic Safety Administration, Washington, D.C., for direct reply to your specific questions.

Ardella J. Pitts Highway Safety Management Specialist

MINNESOTA CLAIMS SERVICES

March 29, 1978

Department of Transportation National Highway Traffic Safety Administration

ATTENTION: Safety Standards Department

RE: Vehicle Involved: 1972 Plymouth Cricket

Vehicle Serial No.: 4C41L2R213949

Gentlemen:

Presently we are investigating an accident in which the driver of the subject vehicle sustained fatal injuries when she collided with the steering wheel as a result of an accident.

Kindly supply us with the following information:

1) Do vehicle standards on this model permit non-collapsible steering column?

2) Did the steering column in these vehicles pass all of your safety requirements at the time?

3) Was the manufacturer permitted to relax steering column safety standards on these vehicles because of hardship?

We will appreciate your assistance in answering these questions and in supplying us with any additional information which may be pertinent on this vehicle.

Wayne C. Parsil