Interpretation ID: nht68-3.45

DATE: 07/29/68

FROM: AUTHOR UNAVAILABLE; Robert M. O'Mahoney; NHTSA

TO: Lotus Cars Limited

TITLE: FMVSS INTERPRETATION

TEXT: Mr. Bridwell has asked that I reply to your letters dated November 18 and July 3 which ask if Motor Vehicle Safety Standard No. 201 requires your company's "Elan Convertible" to have sun visors.

The National Highway Safety Bureau recognizes that the requirement for every passenger car to have two sun visors of energy-absorbing material with mountings that have no rigid material edge radius of less than 0.125 if statically contactable by a 6.5 inch diameter head form, may create a problem for manufacturers of certain types of vehicles. However, the requirement will, on balance, contribute to the safety of the general public.

Compliance with the requirement can and should be made in a manner so as to increase occupant protection.

LOTUS

JULY 3, 1968.

Lowell K. Bridwell, Federal Highway Administrator US Department of Transportation,

Federal Motor Vehicle Safety Standard Number 201: Sunvisors

We despatched a petition to you on 28th November 1967, requesting that we be permitted to substitute increased header padding for the sunvisors stipulated in F.M.V.S.S. 201 on our model: ELAN CONVERTIBLE.

On 19th January we sent further information to back up our earlier submission. We felt, for reasons given in our letter of 28th November 1967, that the spirit of F.M.V.S.S. 201 would be met, on this particular model, better, by increased padding, than by the addition of sunvisors.

We would be extremely grateful for some indication of your view of our petition.

B.A. Luff General Manager