Interpretation ID: 86-5.38

TYPE: INTERPRETATION-NHTSA

DATE: 10/27/86

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Mr. Tsuyoshi Shimizu

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. Tsuyoshi Shimizu Vice-President MMC Services, Inc. 3000 Town Center - Suite 1960 Southfield, MI 48075

Dear Mr. Shimizu:

Thank you for your letter requesting an interpretation of Standard No. 201, Occupant Protection in Interior Impact. You asked how the instrument panel impact protection requirements of S3 of the standard would apply to an occupant compartment interior described in your letter. In particular, you asked whether the "center console" described in your letter would be considered a console assembly that is exempt from the requirements of S3.1 of the standard. I hope the following discussion answers your questions.

S3.1 of the standard sets forth the head impact protection requirements for the instrument panel. S3.1.1, in turn, sets out several exemptions to the instrument panel performance requirements. S3.1.1(a), which provides that the performance requirements do not apply to "console assemblies," is the first exemption which is relevant to your design. As depicted in your letter, there is a short structure, which you referred to as the center console, that is mounted on the floor of the vehicle and is located primarily between the vehicle seats. The gear shift lever is mounted in this structure. Although the structure is connected to the bottom of the instrument panel, you pointed out that there is a "gap," which appears to be an indentation, between "the instrument panel and the center console which makes the console and instrument panel area dist? and separate areas."

The purpose of the head impact requirement is to ensure that portions of a vehicle's instrument panel which are mounted forward of the front seat and are likely to be struck by an occupant's head in a frontal impact provide adequate protection. Thus, the head impact protection requirements apply primarily to the upper portions of the instrument panel. As stated in an interpretation letter of January 12, 1983, to the Blue Bird Body Company, the agency considers the instrument panel to the vehicle structure below the windshield used to mount a vehicle's gauges. Since the "center console" described in your letter is a low-lying structure mounted on the floor and lies primarily between the vehicle seats, the agency would consider it to be a console assembly rather than a part of the instrument panel.

The second exemption which is relevant to your design is S3.1.1(e) of standard. That section exempts areas of the instrument panel that are "below any point at which a vertical line is tangent to the rearmost surface of the panel." The area labeled section B in your diagram is such an areas and thus does not have to meet the performance requirement of S3.1. The exemption of S3.1.1(e) would also apply to the "center console" depicted in your diagram, since it also lies below the point which a vertical line is tangent to the rearmost surface of the panel. The area labeled section A in your diagram is covered by the standard thus would have to meet the requirements of S3.1.

If you need further information, please let me know.

Sincerely,

Erika Z. Jones Chief Counsel

Ms. Erika Jones, Chief Counsel National Highway Traffic Safety Administration U.S. Department of Transportation 400 Seventh Street, S.W. Washington, DC 20590

This letter serves to request an interpretation of FMVSS 20. Occupant Protection in Interior Impact, for the passenger vehicle interior which is cross-sectioned in the enclosure.

S3.1.1 (a) and (e) of 49 CFR 571.201 describes that console assemblies and areas below any point at which a vertical ? tangent to the rearmost surface of the panel do not apply to the requirements of S3.1.

We believe that the "center console" shown in the cross-section should be considered a console assembly by virtue of a gap between the instrument panel and the center console which ? the console and instrument panel area distinct and separate areas. The impact area would be the upper portion from the rearmost surface (see Section A). Section B would be the area below any point at which a vertical line is tangent to the rearmost surface of the panel.

Please inform us in a timely manner whether our interpretation is correct. If you have any questions, please contact me at (313) 353-5444.

Sincerely,

Tsuyoshi Shimizu Vice-President MMC Services, Inc.