Interpretation ID: aiam1461
Director
Automotive Safety Office
Ford Motor Company
The American Road
Dearborn
MI 48121;
Dear Mr. Eckhold: This is in reply to your November 21, 1973, petition for amendment o Federal Motor Vehicle Safety Standard No. 215, *Exterior Protection*, requesting that a more specific bumper pendulum impact pattern be adopted.; The revisions you have proposed could result in designs with less tha required protection in areas outside those specified by Ford. Although the impact points suggested by Ford may constitute an adequate testing pattern for Ford vehicles, they may not be adequate for all other manufacturers' vehicle designs.; The necessity of detecting weak points that you cite is one of the mai goals of the safety standards. To the extent that Ford is confident that such 'searching' is unjustified (because there is no reasonable probability of finding a nonconformity), there is no necessity to search. Structural analysis of each bumper design based upon previous test experience should enable the vehicle manufacturer to determine the critical areas for testing. The manufacturer is free to determine, for example, on sufficient data, that all models need not be tested where the basic bumper design, including the energy absorption unit, is utilized in the models. A further reduction in the need for testing can be realized by a retention of the same bumper designs from year to year.; For these reasons, the NHTSA must deny your request for a more specifi demonstration technique.; Sincerely, James B. Gregory, Administrator