Interpretation ID: 86-3.24

TYPE: INTERPRETATION-NHTSA

DATE: 05/16/86

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Takeshi Tanuma

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. Takeshi Tanuma Nissan Research & Development, Inc. P.O. Box 8650 Ann Arbor, MI 48104

Dear Mr. Tanuma:

Thank you for your letter of February 5, 1986 (ref. W-141-H), concerning the application of Standard No. 201, Occupant Crash Protection in Interior Impact, to an inside door "pull-handle." You explained that the pull-handle is made of unpadded plastic and does not have a hard inside frame. The drawing provided in your letter shows that the pull-handle is 7.44 inches (186 mm) long, 1.12 inches (28 mm) wide, and projects 1.09 inches (27 mm) from the side of the door. I hope that the following discussion answers your questions.

You first asked if the armrest requirements of S3.5 of the standard would apply to the pull-handle if it is located within the pelvic impact area of either the front or rear passenger door. In determining whether the requirements of S3.5 apply to a structure, the agency has looked at the design and location of the structure to determine whether it is an armrest (See, for example, the agency's interpretation letter of September 21, 1983, to Mr. Suzuki of your company.). In this case, the pull-handle projects far enough from the side of the door so that it could be used to rest the arm. Further, if the pull-handle were located in the pelvic impact area, it is likely to be used to rest the arm. Thus, we would consider such a pull-handle located in the pelvic impact area to be an armrest which must meet the requirements of S3.5 of the standard.

You also asked if the pull-handle would have to meet the requirements of S3.5 of the standard if it were located outside of the pelvic impact area at the upper portion of the door. In a conversation with Mr. Oesch of my staff, Mr. Hayaski explained that the pull-handle would probably be located near the rearmost edge of the door. In this case, it appears that the pull-handle would be positioned above and to the rear of where occupants would normally be expected to rest their arms. Thus, we would not consider a pull-handle located in the upper portion of the door and near the door's rear edge to be an armrest.

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

Sincerely, Erika Z. Jones Chief Counsel

February 5, 1986 Ref : W-141-H

Ms. Erika Jones Chief Counsel National Highway Traffic Safety Administration 400 7th St., S.W. Washington, D.C. 20590

Dear Ms. Jones:

Re: REQUEST FOR INTERPRETATION - FMVSS 201, "OCCUPANT PROTECTION IN INTERIOR IMPACT"

On behalf of Nissan Motor Co., Ltd. of Tokyo, Japan, Nissan Research & Development, Inc. herewith requests interpretation regarding the applicability of Federal Motor Vehicle Safety Standard 201, "Occupant Protection in Interior Impact," to an inside door "pull-handle" as shown below.

(Please insert graphics)

Material Description :

- Plastic, unpadded - Without any hard (for example, metal) inside frame

Question 1.

If such a small handle is located within the "Pelvic Impact Area" of the door of either the front or rear passenger areas, is Section 3.5 of FMVSS 201 (the armrest requirement) applicable to this kind of feature?