Interpretation ID: aiam2846
Cars & Concepts
Inc.
12500 E. Grand River
Brighton
MI 48116;
Dear Mr. Abbott: This is in response to your letter dated June 27, 1978, asking whethe fog lamps mounted to the surface of a vehicle bumper are removed prior to testing for compliance with Part 581, *Bumper Standard*.; Vehicles subject to the requirements of Part 581 must comply with th protective criteria of section 581.5(c) (49 CFR 581.5(c)) when tested under the conditions stated in section 581.6 (49 CFR 581.6). The test conditions make no provision for removal of fog lamps prior to testing. As was the case under Federal Motor Vehicle Safety Standard 215, *Exterior Protection*, the Part 581 test procedures provide for removal only of trailer hitches before testing. With the added exception of license plate brackets, excluded from the requirements of Part 581 by interpretation (42 FR 24056, May 12, 1977), other equipment (including fog lamps) attached to the bumper system prior to sale of the vehicle to its first purchaser must meet the damage limitations of the standard.; Sincerely, Joseph J. Levin, Jr., Chief Counsel