Interpretation ID: nht80-2.42
DATE: 06/02/80
FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA
TO: Donald Boyd & Associates, Inc.
TITLE: FMVSS INTERPRETATION
TEXT: This responds to your recent letter requesting confirmation that large commercial truck tractors do not have to comply with Federal Motor Vehicle Safety Standard No. 216, Roof Crush Resistance. You also asked whether large trucks should be designed to comply with the "belt system" option under Safety Standard No. 208, Occupant Crash Protection.
You are correct in your assumption that large commercial trucks would not have to comply with Safety Standard No. 216 since that standard only applies to passenger cars. You are also correct in stating that trucks with a GVWR greater than 10,000 pounds may meet the seat belt option of Safety Standard No. 208 found in paragraph S4.3.2. Under S4.3.1, manufacturers do have the option of meeting the crash protection requirements of S5 by means that require no action by vehicle occupants (with current technology this means air cushion restraints or automatic seat belts). Further, vehicles manufactured prior to August 15, 1977, were permitted to comply with Safety Standard No. 216 in lieu of the "rollover" requirements of Standard No. 208, and for large trucks this would have been a simple test to meet. However, since the vehicle would also have been required to meet the "frontal" and "lateral" requirements by automatic means if option S4.3.1 were taken, no truck manufacturers chose to comply with the "rollover" requirements of Standard No. 208 via the Standard No. 216 option. Rather, seat belts were installed on all large trucks.
SINCERELY,
DONALD BOYD & ASSOCIATES, INC. Consulting Engineers
April 22, 1980
Office of Chief Counsel National Highway Traffic Safety Administration
Re: Roof Structure Crashworthiness Requirements for large commerciales vehicles
Dear Sir:
Based on my review of Federal Motor Vehicle Safety Standards, I have concluded that it is not necessary for manufacturers of large commercial truck tractors to comply with FMVSS roof crash resistance performance standards. However, I would like to get your opinion.
FMVSS 216 relates to passenger cars and, because of the 5,000 pound test load limitation, cannot be expected to apply to large commercial truck tractors which should experience substantially higher forces in most rollovers. Standard number 208; S4.3 applies to "trucks and multipurpose passenger vehicles with GVWR of more than 10,000 pounds" and provides two options for meeting crashworthiness requirements. Realistically, however, it would seem that truck manufacturers should select one of these (the "belt system" option) because the other option (which refers back to 216 and the 5,000-pound load limitation) would not be expected to provide adequate roof structure to resist a 30 mile per hour rollover of a large commercial truck.
Therefore, I have concluded that large commercial truck tractors should be designed to comply with the "belt system" option of FMVSS 208 to provide better occupant protection and, in meeting the requirements of this option, will satisy the occupant crash protection Federal Motor Vehicle Safety Standards for trucks manufactured prior to August 15, 1977.
I would greatly appreciate a response from you indicating whether my interpretation of these requirements is consistent with that of the Office of the Chief Counsel.
Donald E. Boyd, Ph.D., P.E.