Interpretation ID: nht93-7.22

DATE: October 12, 1993

FROM: Saburo Inui -- Vice President, Toyota Motor Corporate Services of North America, Inc.

TO: Robert F. Hellmuth -- Director Office of Vehicle Safety Compliance, NHTSA

TITLE: Test Procedure for FMVSS 214

ATTACHMT: Attached to letter dated 6/28/94 from John G. Womack to Saburo Inui (A42; STD 214)

TEXT: We request confirmation of our interpretation of the means to establish vehicle attitude during the testing for compliance with FMVSS 214, Side Impact Protection, as well as clarification of certain ambiguities in the test procedure.

S6.1, Test Weight, provides that "[e]ach passenger car is loaded to its unloaded vehicle weight, plus its rated cargo and luggage capacity . . . plus the weight of the necessary anthropomorphic test dummies. Any added test equipment is located away from impact areas in secure places in the vehicle."

S6.2, Vehicle test attitude, defines "fully loaded condition" as the "test vehicle loaded in accordance with S6.1."

The term, "fully loaded attitude," used in S6.2, is not defined.

Toyota assumes that the "test weight" described in S6.1 includes the weight of one front seat and one rear seat dummy, but it is not clear whether the "added test equipment" is added to the "test weight" or whether parts of the vehicle (weighing the same as the "added test equipment") are to be removed to keep the vehicle weight at the "test weight." It is also unclear whether the "as delivered" left-to-right attitude must be maintained when adding test equipment.

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We also assume that the term, "fully loaded attitude," describes the attitude of the vehicle in the "fully loaded condition" defined in S6.1 (subject to the requested clarifications). Toyota requests confirmation of that interpretation.

Since these issues can affect compliance with the Standard, we request that NHTSA amend the Test Procedure to ensure that all manufacturers and laboratories employ exactly the procedures in conducting compliance testing.

If you have any questions about this matter, please contact Mr. Soichiro "Chuck" Okudaira of my staff at (202) 775-1707 or our counsel, Donald M. Schwentker, at (703) 799-7447.