Interpretation ID: aiam3000
Vehicle Safety Activities
Sheller-Globe Corporation
3555 St. Johns Road
Lima
OH 45804;
Dear Mr. Premo: This is in response to your letter of February 15, 1979, concerning th definition of 'forward control' vehicle contained in 49 CFR 571.3. Your specific concern is how to measure a vehicle's length to determine if 'the steering wheel hub is in the forward quarter of the vehicle length.'; Overall vehicle length should be determined by measuring the maximu longitudinal distance between the foremost point on the front bumper face bar and the rearmost point on the rear bumper face bar. In the context of the Part 581 Bumper Standard (49 CFR 581), the agency considers bumper guards to be part of the bumper face bar if they are contacted by the impact ridge of the pendulum test device used in compliance testing (43 F.R. 20804, May, (sic) 15, 1978). For the purposes of determining vehicle length, the agency will consider bumper guards as a part of the vehicle bumper face bar and thus included in the measurement of vehicle length. Components such as a permanent or fold-down step which are not associated with the bumper system's function are not considered part of the bumper face far for the purposes of Part 581 Bumper Standard (43 F.R. 40230, Sept. 11, 1978). Therefore, the agency will not consider a permanent or fold-down step as a part of the bumper face bar for the purposes of determining vehicle length.; I have enclosed for your information a notice of proposed rulemakin which would extend Standards No. 201, 203 and 204 to forward control vehicles. The notice also states the agency's intention to eliminate the forward control exemption found in other Federal motor vehicle safety standards.; If you have any further questions, please let me know. Sincerely, Frank Berndt, Acting Chief Counsel