Interpretation ID: nht92-8.17

DATE: March 26, 1992

FROM: Michael J. Sens -- Researcher, S.E.A., Inc.

TO: Paul Jackson Rice -- Chief Counsel, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 4/17/92 from Paul J. Rice to Michael J. Sens (A39; Std. 206; Part 571; Part 567)

TEXT:

By way of this letter, I am seeking an interpretation of FMVSS 206, 214, and 216 as they would pertain to a 1985 Jeep CJ-7. The Jeep CJ-7 was classified (it is no longer in production) by its manufacturer, American Motors Corporation, as a "sport-utility vehicle". The vehicle came with a soft top and a removable fiberglass top option. The side doors are easily removable.

FMVSS 206, "Door Locks and Door Rentention Components," requires at S4. that "components on any side door leading directly into a compartment that contains one or more seating accommodations shall conform to this standard." It goes on to say, "However, components on folding doors, roll-up doors and doors that are designed to be easily attached to or removed from motor vehicles manufactured for operation without doors need not conform to this standard". My first question is: since the 1985 Jeep CJ-7's side doors are easily attached and removed by design for operation in a doorless manner, is it exempt from conformity to FMVSS 206?

FMVSS 214, "Side Door Strength," states at S2. that "this standard applies to passenger cars." The 1985 Jeep CJ-7 is defined by its manufacturer as a "sport-utility vehicle." This classification is not that of a "passenger car." My second question is: since the 1985 Jeep CJ-7 is classified as a "sport-utility vehicle," does FMVSS 214 apply to it?

FMVSS 216, "Roof Crush Resistance-Passenger Cars," states at S3. that "This standard applies to passenger cars." After stating that it does not apply to vehicles that conform to the rollover test requirements of S5.3 of standard 208, it continues, "It also does not apply to convertibles." My third question is: since the 1985 Jeep CJ-7 is classified as a "sports-utility vehicle" and is a convertible, does FMVSS 216 apply to it?

Please find enclosed two views of the type vehicle under discussion. The 1985 CJ-7 shows the soft-top package with the top down and the side doors removed. Unfortunately, I do not have an illustration of the 1985 CJ-7 with the optional hard snap-on top. However, the 1981 CJ-7 model photograph enclosed is typical of how the 1980's CJ-7 line appeared with the optional top.

Thank you in advance for your time and considerations on this issue. If you require additional information, do not hesitate to contact me.

Attachment

Photos and text pertaining to the 1981 and 1985 CJ-7 vehicles.

(Text and graphics omitted)