Interpretation ID: GF008126

Mr. Dietmar K. Haenchen
Safety Affairs and Vehicle Testing
Volkswagen of America, Inc.
Mail Code 3C02
3800 Hamlin Road
Auburn Hills, MI 48326

Dear Mr. Haenchen:

This responds to your letter of November 4, 2003, and subsequent phone conversation with George Feygin of my staff regarding applicability of certain provisions of Federal Motor Vehicle Safety Standard (FMVSS) No. 201 "Occupant protection in interior impact," to sliding interior compartment doors. Specifically, you ask whether a sliding interior compartment door that does not project outward like a pivoting or hinged door would is subject to the requirements of S5.3 of FMVSS No. 201. In short, our answer is yes.

By way of background, the National Highway Traffic Safety Administration (NHTSA) does not provide approvals of motor vehicles or motor vehicle equipment. Under 49 U.S.C. Chapter 301, manufacturers are required to certify that their vehicles and equipment meet applicable requirements prior to the initial sale of the vehicle.

FMVSS No. 201 establishes performance requirements designed to reduce the risk of injury in the event an occupant strikes the interior of a vehicle during a crash. S5.3 of FMVSS No. 201 specifies that doors to interior compartments must remain latched when subjected to certain forces that might be experienced in a crash. The determination of whether an interior compartment door is subject to the requirements of S5.3 is determined by both the location of the door and whether the door fits within the definition of "interior compartment door."S5.3 applies only to interior compartment doors located in the instrument panel, console, seat back or side panels adjacent to a designated seating position. We are assuming that the interior compartment in question is located in either the instrument panel, the console, the seat back or a side panel.

49 CFR 571.3(b) defines "interior compartment door" as "any door in the interior of the vehicle installed by the manufacturer as a cover for storage space normally used for personal effects" (emphasis added). For example, an ashtray is not normally used for storing personal effects, and therefore its cover is not considered to be an interior compartment door. [1] Similarly, the agency has also indicated that a fuse box door [2] and a cup holder door [3] are not interior compartment doors subject to the requirements of S5.3. In your phone conversation with George Feygin you indicated that the interior compartment in question is intended to store personal effects, thus making it subject to the requirements of S5.3.

The agency has never made a distinction between a sliding interior compartment doors and other, pivoting or hinged doors that project outward when opened. In your letter you assert that an open sliding compartment door does not present a potential for occupant injury because an open sliding compartment door does not project outward into the interior of the vehicle. S5.3 of FMVSS No. 201 requires that doors in the console or a side panel remain closed regardless of the method by which a manufacturer chooses to open or close them. The concern that an open door could cause occupant injury when there is a lateral or diagonal impact is not limited to a protrusion created by an open door. Rather, the concern addressed by the requirement is that a sharp or rigid surface does not expose an occupant to undue risk of injury.

I hope you find this information helpful. If you need further assistance, please contact George Feygin of my staff at this address or at (202) 366-2992.

Sincerely,

Jacqueline Glassman
Chief Counsel

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