Interpretation ID: 1985-03.33

TYPE: INTERPRETATION-NHTSA

DATE: 08/21/85

FROM: AUTHOR UNAVAILABLE; Jeffrey R. Miller; NHTSA

TO: Mr. H. Moriyoshi

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. H. Moriyoshi Executive Vice President and Control Manager Mazda (North America), Inc. 24402 Sinacola Court Farmington Hills, Michigan 48018

Dear Mr. Moriyoshi:

Thank you for your letter of July 2, 1985, requesting an interpretation of Federal Motor Vehicle Safety Standard No. 201, Occupant Protection in Interior Impact. You specifically asked whether a design alternative you are considering for an interior storage compartment would have to meet the requirements of S3.3 of the standard. An explained below, we would consider your design to be an interior compartment door assembly and thus subject to the requirements of S3.3 of the standard.

You described your design as an interior surface with an integrated map/magazine compartment. Your proposed design consists of a compartment with a rigid exterior surface that remains open at a fixed width. You said that when a motorist wanted to stow a thicker package in the compartment, the opening could be expanded to a greater width. The drawing accompanying your letter shows that the exterior surface (i.e., the surface nearest to a vehicle occupant) is hinged; the movement of the hinged surface is restricted by a spring. It appears from your drawing that of the spring broke or otherwise became disengaged in a crash, the exterior surface of the compartment would swing open on its hinge and be struck by a vehicle occupant. Such an action is similar to what could happen with the conventional hinged glovebox or other doors in a vehicle. We would therefore consider your proposed design to be a interior compartment door assembly.

I hope this information is of assistance to you. If you have further questions, please let me know.

Sincerely, Jeffrey R. Miller Chief Counsel MAZDA July 2, 1985

Mr. Jeffrey Miller Chief Counsel National Highway Traffic Safety Administration 400 Seventh Street, S.W. Washington, D.C. 20590

Re: Request for Interpretation of Federal Motor Vehicle Safety Standard 201, Occupant Protection In Interior Impact

Dear Mr. Miller,

Mazda has developed several design alternatives for interior storage compartments. Among them is the use of an interior surface with an integrated map/magazine pocket. In many past and current designs, auto manufacturers have utilized rigid molded plastic and flexible vinyl and fabric as the materials with which to provide a map/magazine pocket. On those circumstances, the map/magazine pocket was clearly interpretated by both the NHTSA and the manufacturers as being only a pocket and, therefore, not subject to the performance requirements of FMVSS 201, S. 3.3.

However, in consideration of the concept that Mazda is reviewing, the interpretation of the Standard does not appear so straightforward. Our proposed design consists of a pocket, in the usual sense, that remains open at a fixed width. In situations where a thicker package would be required to be stowed, the rigid pocket opening could be expanded to a greater width. After examination of this design, we have tentatively determined that this would not be considered an "interior compartment door assembly" in the literal sense as it would always be in the open position and subsequently not required to meet the conformance criteria of S. 3.3 of FMVSS 201.

Mazda requests that your office review this matter, with reference to the attached sketch, and indicate how the NHTSA would interpret this design.

Thank you. Sincerely, H. Moriyoshi Executive Vice President and General Manager HM/mLs Attachment