Interpretation ID: nht71-1.50

DATE: 01/29/71

FROM: AUTHOR UNAVAILABLE; C. H. Hartman for D. W. Toms; NHTSA

TO: Morgan Motor Company, Ltd.

TITLE: FMVSS INTERPRETATION

TEXT: By letter of November 19, 1970, you petitioned for reconsideration of Federal Motor Vehicle Safety Standard No. 214 - Side Door Strength (35 F.R. 16801, October 30, 1970). After consideration of the issues raised by Morgan's petition, the National Highway Traffic Safety Administration has found no sufficient justification for amending the standard and the petition is therefore denied.

Your company's petition states that the standard presents difficulties for cutaway doors, and that the structure of Morgan automobiles supplies a measure of protection through Clared side fenders that extend beneath the doors. The Administration recognizes that there is considerable variety in door and side structure. However, the need to protect occupants of all vehicles from injury in side collisions dictates a uniform measure of such protection, and the Administration has determined that the requirements of Standard No. 214 are reasonable, practicable and appropriate for passenger cars.

The remaining points in your letter of November 19, 1970, are more nearly questions for interpretation than requests for reconsideration. Your second question pertains to the height (or length) of the loading device. The standard states only that the device must not contact any structure above the bottom edge of the door window opening. There is no other restriction on the maximum height of the test device, and it is not clear, without further explanation, why Morgan would be limited to a cylinder only 4 inches high.

Your remaining question deals with the positioning of side windows. Although the standard specifies that side windows shall be in the uppermost position, it does not require that side windows exist and should not be so interpreted.