Interpretation ID: aiam4168
Director
Automotive Safety Office
Ford Motor Company
The American Road
Dearborn
MI 48121;
Dear Mr. Munson: This is to follow-up on a phone conversation between Mr. William Kin of Ford Motor Company's Washington Office and Stephen Oesch of my staff concerning the initial knee spacing requirements of Standard No. 208, *Occupant Crash Protection*. Mr. King referred to a memorandum in the public docket on Standard No. 208 which summarizes a meeting held between representatives of General Motors Corporation (GM) and this agency on April 16, 1986, and asked when the agency plans to reinstate the 14.5 inch requirement for the initial spacing of the driver test dummy's knee's (sic).; As discussed in the memorandum summarizing the April 16, 1986 meeting the agency misinterpreted the comments made by GM and Honda Motor Company on the initial knee spacing requirement proposed in April 1985. As a result of that misinterpretation, the agency adopted a (sic) 11 3/4 requirement for the initial spacing of the driver test dummy's knees in the March 21, 1986 final rule on the test dummy positioning procedures, rather than the proposed 14 1/2 inch requirement. The memorandum said that the agency planned to publish a correction notice on the test dummy positioning procedure to reinstate the 14 1/2 dimension for the initial spacing of the driver test dummy's knees.; Subsequent to the April 16, 1986 meeting, Ford filed a petition fo reconsideration of many of the test dummy positioning and other requirement (sic) adopted in the March 1986 final rule. The agency will make the necessary correction to the initial knee spacing requirement for the test dummy at the time it responds to Ford's petition for reconsideration.; Manufacturers can rely on this letter, which will be placed in th public docket on Standard No. 208, as assurance that they can use the 14 1/2 inch initial knee spacing requirement for the driver test dummy in conducting compliance tests for Standard No. 208.; If you have any further questions, please let me know. Sincerely, Erika Z. Jones, Chief Counsel