Interpretation ID: nht73-4.43

DATE: 08/08/73

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: DPD Mfg. Co., Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of July 31, 1973, in which you asked our opinion as to the effect of Standard 208 upon your vehicle air conditioner installations.

Standard 208, Occupant Crash Protection, for the next few years allows manufacturers the option of providing either seat belts or passive protection systems, of which the air cushion is presently the most widely considered, in various combinations. The decision as to when passive protection would become mandatory has not yet been made.

The passive protection requirements of Standard 208 are measured with instrumented dummies, and the standard does not specifically regulate the method by which manufacturers provide the protection in the various crash tests. The way a manufacturer chooses to meet the standard, including the arrangement of the components of the vehicle interior, is thus left to his own discretion and the NHTSA does not offer opinions as to particular vehicle designs.

The "vacuum advance system" you refer to evidently refers to the air pollution control programs of the Environmental Protection Agency. That agency's address is Washington, D.C. 20460.

Yours Truly,

dpd mfg. co., inc.

July 31, 1973

The Office of the Chief Counsel National Highway Traffic Safety Administration

We manufacture air conditioners for small cars imported into the United States Accordingly, we are interested in providing units which will not interfer with vehicle safety devices.

Our 1973 air conditioners are usually installed under the dash or in center console. See attached photos of our air conditioners installed and the vehicle without air conditioning.

We have heard that a vacuum advance system may be under consideration and the air-bag protection system would definitely bear on our future design of air conditioners. Also, we need your opinion as to the effect of Law 208 upon our air conditioners.

The above information is most urgently requested since we are proceeding rapidly with the 1974 air conditioners.

Thanking you in advance for an early reply.

O. D. Hunter Director of Training and Publications

Enclosures