Interpretation ID: nht81-2.17

DATE: 04/28/81

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: N. B. Echelberry

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to the vehicle owner's questionnaire you forwarded on March 9, 1981, concerning the installation of computer terminals in patrol cars assigned to the city of Miami Police Department. The questionnaire was recently forwarded to my office for reply. You asked whether the installation violated any safety standards.

Federal Motor Vehicle Safety Standard No. 201, Occupant Protection in Interior Impact, a copy of which is enclosed, specifies performance requirements for the instrument panel. It can't be determined from the information you provided whether the terminals are located within an area of the vehicle covered by that standard. The standard generally regulates only the upper portion of the dashboard. If it is located within the regulated zone, the installation of the computer terminal on the vehicle's instrument panel may be affected by section 108(a)(2)(A) of the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1397(a)(2)(A). That section provides that:

No manufacturer, distributor, dealer or motor vehicle repair business shall knowingly render inoperative, in whole or part, any device or element of design installed on or in a motor vehicle or item of motor vehicle equipment in compliance with an applicable Federal motor vehicle safety standard. . . .

Modification of the instrument panel by a manufacturer, distributor, dealer or motor vehicle repair business during the installation of the computer terminals so that it no longer complies with Standard No. 201 would be a violation of section 108(a)(2)(A).

If you have any further questions, please let me know.

DEPARTMENT OF TRANSPORTATION NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION VEHICLE OWNER'S QUESTIONNAIRE

HL NO.: (Illegible Words)

OWNER

LAST NAME: ECHELBERRY FIRST NAME & MIDDLE INITIAL: NORMAN B. TELEPHONE NO. (Area Code): Work- 579-6540 Home- 579-6111

STREET ADDRESS: 2514 SHERMAN ST. CITY: HOLLYWOOD STATE: FL. ZIP CODE: 33020

VEHICLE INFORMATION

VEHICLE MAKE & MODEL: PLYMOUTH VOLARE MODEL YEAR: 79-80 BODY STYLE: 4 DR. VEHICLE IDENTIFICATION NO.: UNK.

ENGINE SIZE (CID/CC): UNK. [X] GAS [] DIESEL MILEAGE: UNK DATE PURCHASED: [X] NEW [] USED DEALER'S NAME AND ADDRESS: AIR CONDITIONED: [X] Yes [] No

VEHICLE SPEED AT FAILURE: [] Parked NO. CYLINDERS: 8 POWER STEERING: [X] YES [] NO POWER BRAKES: [X] YES [] NO TRANSMISSION MANUAL (Speed): AUTOMATIC [X] Yes [] No [] 3 [] 4 [] 5 TYPE

FAILED COMPONENT/PART INFORMATION

COMPONENT/PART NAME: LOCATION: [] Left [] Right [] Front [] Rear FAILED PART: [] Original [] Replacement MILEAGE AT FAILURE: NO. OF FAILURES:

DESCRIPTION OF FAILURE: (OVER)

FAILED TIRE INFORMATION

MANUFACTURER: TIRE NAME: SIZE: TYPE FAILURE:

CONSTRUCTION: [] Belted [] Bias [] Radial FAILED TIRE: [] Original [] Replacement BELT MATERIAL: [] Steel [] Fiberglass [] Aramid [] Rayon LOCATION: [] Right Front [] Right Rear [] Left Front [] Left Rear [] Spare DOT IDENTIFICATION NO. *:

* The identification number consists of about ten letters and numerals following the letters DOT usually located near the rim flange on the side opposite the whitewall or on either side of a blackwall tire.

APPLICABLE ACCIDENT INFORMATION

ACCIDENT: [X] Yes [] No NO. INJURIES: UNK.- INFO NOT AVAILABLE NO. FATALITIES: 0

DESCRIPTION OF ACCIDENT: OVER SIGNATURE OF OWNER: (Illegible Words) DATE: 2-20-81

DESCRIPTION OF PROBLEM

I am employed by the City of Miami Police Dept.-400 NW 2 Ave Miami, Fl. Currently, nearly our entire fleet of patrol cars have had computer terminals installed in them. These terminals are approx. 12" x 12" x 18" high. They protrude from the center dashboard into the area over the front seat. Two thin metal brackets support this terminal. There have been accidents where our officers were injured as a result of this installation. I have made several inquiries to different agencies to determine if this is indeed a violation of a safety standard. I received your agencies name to send a request to.

Please respond if I have contacted the wrong agency. This is a serious matter, particularly for passengers in the front right side. These items are going to be installed in vehicles due for a near future delivery.

Thank you for your attention on this matter.

(Illegible Words)