Interpretation ID: aiam1942
Vice President
American Mutual Insurance Alliance
20 North Wacker Drive
Chicago
IL 60606;
Dear Mr. Segraves: This is in response to your letter of May 9, 1975, expressing you opposition to any bumper requirement that would permit the elimination of the energy absorbers from motor vehicle bumper systems.; Your letter refers to a statement made by Mr. James Schultz in a May 7 1975, letter responding to your request for information concerning the cost-benefit trade-off involved in permitting damage to the bumper face bar components and associated fasteners. Mr. Schultz's comment that 'the proposed schedule for implementation of the surface damage criteria would not effect a lowering of the current level of bumper performance' was directed only at the exterior surface damage provisions which are proposed as part of a Part 581 damageability standard under the Motor Vehicle Information and Cost Savings Act (Pub. L. 92-513).; With regard to the provisions of Standard No. 215, *Exterio Protection*, the National Highway Traffic Safety Administration's action to reduce the number of required longitudinal pendulum impacts was taken to bring the test requirements more in line with real-world conditions. As was explained in the May 7 letter, the number of required pendulum impacts has been revised to conform to the average number of low-speed impacts a vehicle will encounter in its lifetime. The ability of a vehicle to comply with the pendulum test requirements will therefore assure its ability to withstand the number of low-speed collisions in which it is likely to be involved.; We are not able to predict whether the reduced number of impacts wil enable removal of the energy absorbing devices from the bumper system. Nissan has stated that they will not be able to eliminate the energy absorbers. However, it remains possible that some manufacturers could at least reduce the size of the components.; Yours truly, Richard B. Dyson, Assistant Chief Counsel