Interpretation ID: nht78-1.4

DATE: 12/06/78

FROM: AUTHOR UNAVAILABLE; J. J. Levin, Jr.; NHTSA

TO: Saab-Scania of America, Inc.

TITLE: FMVSS INTERPRETATION

TEXT:

NOA-30

Mr. Ralph T. Millet Director, Governmental Relations Saab-Scania of America, Inc. Saab Drive, P. O. Box 697 Orange, Connecticut 06477

Dear Mr. Millet:

This is in response to your letter of 25 October 1978 concerning the requirements of S3.3 of Standard No. 201 as it applies to the instrument panel compartment door in the Saab 900. Your specific concern is the portion of S3.3 that provides, "Additionally, any interior compartment door located in an instrument panel or seat back shall remain closed when the instrument panel or seat back is tested in accordance with S3.1 and S3.2."

According to your letter, the hinges on the Saab 900 instru- ment panel compartment door are designed to deform to keep the compartment door closed if deformation resulting from the head impact requirements of S3.1 is great enough to open the compartment latch.

If the instrument panel compartment door remains closed during the head impact tests of S3.1, the vehicle complies with that aspect of the requirements of S3.3 of Standard No. 201. The standard does not specify that the latch mechanism remain closed, only that the door "shall remain closed."

This interpretation should not be construed as an approval of Saab's instrument panel compartment door hinge system. Federal motor vehicle safety standards are written primarily in terms of performance requirements which must be met in specified tests, and a manufacturer is free to use any design it wishes to meet those performance requirements. Thus, this agency does not grant approval of specific systems or components in the vehicle. The manufacturer must exercise due care to assure that its vehicles comply with all applicable safety standards.

Please let me know if you have any further questions.

Sincerely,

Joseph J. Levin, Jr. Chief Counsel

Chief Counsel October 25, 1978

Chief Counsel National Highway Traffic Safety Administration U.S. Department of Transportation Washington, D. C. 20590

Subject: Interpretation of Paragraph S3.3 of FMVSS 201

Dear Sir:

Paragraph S3.3 of Federl Motor Vehicle Safety Standard #201 states:

"Interior compartment doors. Each interior compartment door assembly located in an instrument panel, console assembly, seat back, or side panel adjacent to a designated seating position shall remain closed when tested in accordance with either S3.3.1(a) and S3.3.1(b) or S3.3.1(a) and S3.3.1(c). Additionaly, any interior compartment door located in an instrument panel or seat back shall remain closed when the instrument panel or seat back is tested in accordance with S3.1 and S3.2. All interior compartment door assemblies with a locking device must be tested with the locking device in an unlocked position.

When the Saab 900 instrument panel and compartment door is so tested, the compartment door remains in a closed position.

However, in certain head form impact directions, it may occur that the latch disengages and no longer keeps the door closed.

The only acceptable solution we could find to this problem was to design the hinges of the compartment door so that if the deformation after impact is large enough to open the latch, the hinges will deform in such a way that the door thereby remains closed.

We would appreciate your opinion as to whether or not the door remaining closed by the designed locking action of the hinges is considered to be in compliance with Paragraph S3.3 of the Standard.

Very truly yours,

SAAB-SCANIA OF AMERICA, INC.

Ralph T. Millet Director, Governmental Relations

RTM:s