Interpretation ID: aiam0637
Vice President
Product Development and Purchasing
Chrysler Corporation
Detroit
MI 48231;
Dear Mr. Bright: Your letter of February 18, 1972, dealt with three aspects of Standar 215 that continue to be of concern to Chrysler and with one feature of Standard 210 that you regard as inappropriate.; Your first problem with Standard 215 is the requirement for corne impacts at heights below 20 inches. Our response to the objections raised by Chrysler and others when this requirement was made a part of the standard was to grant an additional two years for compliance. We did this in the expectation that the additional time would permit the manufacturers to make the necessary changes within their normal tooling cycle.; The agency considered the corner impact requirement to be justified and it is not now persuaded to the contrary. We would be willing, however, to review any additional information you can provide on the subject of the costs and benefits of the improved corners.; Your second concern has also been expressed at several points in th rulemaking process. In response to comments advocating the use of resilient materials in the bumper itself, the standard was amended to specify a broader impact ridge, rather than to specify the resiliency of material with which contact would be permitted. The agency has not considered the styling effects of the pendulum requirement to be sufficient to justify amending the standard to permit cosmetic additions of the type you describe. Of course you are free to submit additional information to support the need for such an amendment.; The photometric requirements from Standard 108 that are proposed fo incorporation in Standard 215 have been the subject of several comments under Notice 10 in Dockets 1-9 and 1-20. The issue has not been resolved by issuance of a final rule and we will therefore consider your remarks as an addition to Chrysler's comments on Notice 10.; In the area of seat belt anchorages, the question of whether to us dynamic or static test methods was resolved in October 1970 by specifying a static test with a 10-second holding period. It was thought that this was the surest means of testing the basic strength of the metal and that it therefore carried out the original intent of the standard. Although it may be that the resulting anchorages are able to withstand barrier crashes at speeds considerably higher than 30 mph, we do not consider this to be sufficient cause for relaxing the anchorage requirement. If you have information concerning the force levels at which accidents are survivable, and the relation of these levels to anchorage strength, we would be glad to receive this information.; Sincerely, Douglas W. Toms, Administrator