Interpretation ID: nht72-3.7

DATE: 11/14/72

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Nissan Motor Co., Ltd.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of September 13, 1972, on the subject of S3.5.1(b) of Motor Vehicle Safety Standard No. 201.

The terms "energy absorbing material" and "rigid material", as used in Standard 201, are not rigorously defined. According to your letter, the material used in the arm rest can be depressed to within 1.25 inches of the test surface by an evenly distributed force that does not exceed 100 pounds per square inch. This force does not appear to be excessive, and we would therefore consider the material to be "energy absorbing material".

The "rigid material" with which contact is prohibited at distances greater than 1.25 inches from the test surface would include such components as brackets, channels and braces, most of which are commonly metallic. We do not rule out the possibility that in some instances a metallic component may be used expressly to absorb energy, but in the usual case a metallic part would be considered "rigid material" and contact with it would result in violation of S3.5.1(b).

TRULY YOURS,

NISSAN MOTOR CO., LTD.

September 13, 1972

Lawrence R. Schneider National Highway Traffic Safety Administration

Dear Mr. Schneider:

Subject: Interpretation of MVSS 201; Occupant Protection In Interior Impact

This is to ask your interpretation of MVSS 201; S3.5.1(b) (armrests) which states, "It shall be constructed with energy absorbing material* that deflect or collaspses to within 1.25 inches of . . .without permitting contact with any rigid material. '* is not distinguishable, therefore the following is our own interpretation:

a) If the surface pressure which is calculated from the load equivalent to deflection 1.25 inches on the load-deflection curve measured during the test as shown in Figure 1, is not more than 100 pounds per square inch, we consider the tested material as the energy absorbing material.

b) We consider metalic material as rigid material.

If you feel you could improve upon the above, your prompt reply would be greatly appreciated.

* The underscoring is for your personal reference.

Tatsuo Kato Engineering Representative Liaison Office in USA

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