Interpretation ID: aiam3758
Office Manager
Mazda (North America)
Inc.
23777 Greenfield Road
Suite 462
Southfield
MI 48075;
Dear Mr. Nakaya: This responds to your letter of August 25, 1983, requesting a interpretation of the requirements of Standard No. 201, *Occupant Protection in Interior Impact*. Your specific questions concern the application of the requirements of S3.5.1(b) of the standard to an armrest.; The answers to your four questions are as follows: A) The requirements of S3.5.1(b), as with the requirements o S3.5.1(a), apply to the whole area of an armrest. In contrast, the requirements of S3.5.1(c) only apply to a part of an armrest (i.e., the portion of the armrest within the pelvic impact area).; B) See answer to A. C) The agency does not give prior approval to specific designs. I appears, however, that your design would not comply, since apparently the armrest will not deflect or collapse to within 1.25 inches of a rigid test panel surface without permitting contact with any rigid material, in this case the power window switch. In addition, the power window switch apparently does not have a minimum vertical height of not less than one inch. It is difficult to provide you with a definitive answer since section A-A of your drawing appears to be drawn to a different scale than the scale shown in the lower left corner of your drawing.; D) It appears from your drawing that even if the requirements o S3.5.1(b) were amended, as you suggested, to limit their application to the pelvic impact area of the armrest, the design would not comply since the power window switch area of the armrest is within the pelvic impact area. Rather than seeking an amendment to the standard, you may want to consider modifying your design so that it will comply with either 3.5.1(a) or (c) of the standard.; If you have any further questions, please let me know. Sincerely, Frank Berndt, Chief Counsel