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Interpretation ID: LWP008657

    Mr.Robert Babcock
    Manager, Corporate Affairs
    Hyundai-Kia America Technical Center, Inc.
    6800 Geddes Road
    Superior Township, MI 48198


    Dear Mr.Babcock:

    This responds to your letter asking about Federal Motor Vehicle Safety Standard (FMVSS) No.201s requirements for instrument panels, set forth in S5.1.You ask whether an interior component contiguous to the instrument panel of a future model shown in a photograph and diagram you submitted would be excluded from meeting S5.1 under a provision of S5.1.1 of the standard.Our answer is yes.(We note that by letter dated November 3, 2005, you removed the request for confidentiality related to your interpretation request.)

    The photograph shows an instrument panel (dashboard) of a vehicle.The instrument panel forms a T-shape design with a contiguous structure that contains the gear shift lever and some dials and compartments.The design is visually similar to "one-piece" dashboard and console assemblies that do not have a space separating the dashboard from the console assembly.However, in your design, the contiguous structure containing the gear shift lever does not extend all the way rearward between the driver and passenger seats.It extends less than a foot below the instrument panel.

    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.Certain areas within the vehicle must be properly padded or otherwise have energy absorbing properties to provide head protection in the event of an impact.The requirements for instrument panels are set forth in S5.1.S5.1 states, "Except as provided in S5.1.1, when that area of the instrument panel that is within the head impact area is impacted" by a head form, the deceleration of the head form shall be within specified limits.The exceptions relevant to your letter are S5.1.1(a) and (e).

    S5.1.1(a) of FMVSS No.201 excludes console assemblies from the head impact protection requirements of the standard.Although console assemblies are not defined in FMVSS No.201, we have noted in previous interpretations that we regarded a "low-lying structure mounted on the floor and [lying] primarily between the vehicle seats" to be a console assembly. (September 21, 1988 letter to Mr.Hiroshi Kato; October 27, 1986 letter to Mr.Shimizu.)The structure you ask about in your design does not extend between the seats and is not "mounted to the floor". It is thus different from structures we called console assemblies in the past.

    However, S5.1.1(e) of FMVSS No.201 excludes from the head impact protection requirements "[a]reas below any point at which a vertical line is tangent to the rearmost surface of the panel". You suggest that the rearmost surface of the instrument panel in this vehicle is the rearmost surface of the dashboard at the right front passenger seating position.Based on your letter, we agree with you that the line you have drawn on your photograph shows the rearmost surface of the instrument panel.Areas below any point at which a vertical line is tangent to that rearmost surface are excluded from S5.1.

    If you have further questions, please contact us at (202) 366-2992.

    Sincerely,

    Stephen P.Wood
    Acting Chief Counsel

    ref:201
    d.1/24/06