Interpretation ID: nht70-2.26

DATE: 09/21/70

FROM: AUTHOR UNAVAILABLE; D. W. Toms; NHTSA

TO: Donald O'Neill

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of August 17, 1970, concerning Mr. George R. Smith's comments on the energy-absorbing steering system in response to my interview in your August issue.

I did not mean to imply that energy-absorbing steering systems were not installed by some manufacturers, such as General Motors, prior to the effective date of our Federal Motor Vehicle Safety Standard No. 203 - Impact Protection for the Driver from the Steering Control System.

Mr. Smith is correct in noting that Standard No. 203 does not require collapsible steering columns. It was intentionally written in performance terms rather than as a design specification. Most manufacturers chose the collapsible steering column to meet the standard, hence the common use of the term "collapsible column" to refer to our requirement. However, it should be noted that the standard is also being complied with by steering control systems employing other methods of energy-absorption including energy-absorbing rims and a collapsible bellows located forward of the steering wheel hub.

Regarding your request for a copy of the National Highway Safety Bureau "Program Plan for Motor Vehicle Safety Standards," this plan is a working document and represents the presently scheduled rulemaking actions to be issued by our Motor Vehicle Programs activity during the period of 1970-1972. I am pleased to enclose a copy as you requested.

I appreciate the opportunity to clarify some of my interview remarks and I enjoyed reading Mr. Smith's comments.

ENCLOSURE