2nd row ford transit seats in NV 3500 high roof

There are some new rules coming out about 2nd row occupant crash stuff which will apply to newer models in the coming years which got me thinking about installing a sacrificial impact panel on the 2nd row driver side. Mercedes will have to upgrade that crew van option to comply moving forward. I think the law is regarding interior panels and having no exposed metal in a passenger area including the roof. Disclaimer- this is all my own home grown engineering, anything you do to your van is your own liability. That said I used trunk liner to carpet the factory panels and installed 1 1/2 crash foam laminated with a bubble foil radiant barrier on both sides in the window depression. The thinking is the 1/8" factory panel is weak enough to give under a side impact and the foam acts like a bike helmet. Better than a exposed metal panel in any case. In hind sight the 1 1/2" foam was a bit thick with the radiant barrier lamination.