Interpretation ID: aiam3008
General Manager
Nissan Motor Co.
Ltd.
Engineering Office of North America
P.O. Box 1606
560 Sylvan Avenue
Englewood Cliffs
NJ 07632;
Dear Mr. Maeda: This is in response to your letter of April 19, 1979, asking whether tie down hook located beneath a vehicle between the rear main body and the rear bumper is considered a vehicle exterior surface for purposes of section 581.5(c)(10) of the Part 581 Bumper Standard (49 CFR 581.5(c)(10)). You state that this component may experience some paint separation on contact with the vehicle bumper face bar during pendulum and barrier impact testing.; >>>Section 581.5(c)(10) provides that, 'For vehicles manufactured on or after September 1, 1979, the exterio surfaces, except the bumper face bar, shall have no separations of surface materials, paint, polymeric coatings, or other materials from the surface to which they are bonded ...'<<<; when subjected to the specified pendulum and barrier tests. A component located on the vehicle underbody behind the bumper face ba is not an exterior surface for purposes of section 581.5(c)(10). For this reason, the tie down hook you describe would not be subject to the requirements of that section.; Sincerely, Frank Berndt, Acting Chief Counsel