I'll just say it again. The COG of the APV is not that high off the ground as all the heavy bits are underneath the vehicle. Considering the hood is almost to my chest already, there's virtually nothing in the 'engine compartment'. The engine is set low (and a bit on its side making it even lower) at knee level. Just as high as you'd find in your average sedan. Heavy bits like the frame, suspension, tranny, etc. are all set low (lower than say your average 4x2 pick up). About the only thing mounted high is the greenhouse.
And since the vehicle was never tested by the NHTSA, no one will really know if it will pass their crash standards. However, from an equipment standpoint, it will not comply (just like most local vehicles). The absence of side marker lamps alone is in violation of Federal standards. Just the same, the Avanza is also not NHTSA-approved and is also a rolling list of Fedral violations. So I guess its even-steven. It would not be proper to simply judge a vehicle as unsafe just because it is not sold in the USDM. Toyota Fortuners, Toyota Innovas, Nissan Patrols, Nissan Mistrals, etc. are also not sold in the USDM and are pretty much in non-compliance with FMVSS.
The Nissan Vanette, Mitsubishi L300 [star wagon body], along with other forward control vans did pass Federal standards at the time of their sale in the USDM. However, I still don't regard them as being 'safer' than other vehicles on the road.
The Samurai complied with all pertinent Federal Motor Vehicle Safety Standards in enforcement during the time of its sale. It was Consumer Reports Magazine who kept declaring it 'Unacceptable' along with the Isuzu Trooper/Acura SLX and the Mitsubishi Montero. Slow sales and newer regulations were what took it off the market. It would have been too expensive to reengineer the Samurai considering the relatively low volumes it has always sold (it was a niche market vehicle) in the U.S.