Interpretation ID: aiam1863
23138 Demley Drive
Mt. Clemens
MI 48043;
Dear Ms. Apone: This is in response to your letter of March 21, 1975, commenting on th National Highway Traffic Safety Administration's (NHTSA) January 2, 1975, proposal to reduce the performance requirements of the Federal bumper standard.; The proposal was based primarily on the results of two agency-sponsore studies which indicated that the cost and weight of many current production bumpers, in light of inflation and fuel shortages, made the bumpers no longer cost-beneficial. Information presented at public hearings on the bumper notice and comments submitted to the docket in response to the proposal brought to light additional data. The NHTSA carefully examined all of this evidence and reviewed its studies in light of the new information. As a result, the agency concluded that the existing 5 mph protection level should not be reduced. This decision is contained in a Federal Register notice that was published March 12, 1975 (Docket No. 74-11, Notice 7, Docket No. 73-19, Notice 6.)(sic); I would like to point out that the bumper standard, as it currentl exists, has no direct effect on occupant safety in collisions. The safety benefits of the standard relate to the prevention of damage to safety-related components such as headlmaps (sic), fuel and cooling systems and exhaust systems. It is the after-crash dangers that would exist if a vehicle were driven with any of the specified vehicle systems inoperative that the standard focuses on. Therefore, a reduction in the performance requirements would not expose occupants to greater hazards during a collision itself.; We appreciate your interest. Yours truly, Richard B. Dyson, Assistant Chief Counsel