Interpretation ID: aiam1984
President
Humanoid Systems
Division of Alderson Biotechnology Corporation
5250 El Segundo Boulevard
Hawthorne
CA 90250;
Dear Mr. Alderson: This is in response to your letter of June 27, 1975, criticisin certain aspects of the Part 572 dummy specifications in light of difficulties you have encountered in making test dummies.; You may have misunderstood the June 26 conversation with Dick Dyson o our Chief Counsel's Office that you mentioned. In his conversation with you, as Dick said at the time, he was simply paraphrasing the letter from Bob Carter that on that day was on its way to you in response to your letter of May 30. His (and the letter's) point was that dummies are not items of motor vehicle equipment, that there is therefore no Federal requirement for their certification, that any deviation from the Part 572 specifications is purely a matter of private negotiation between dummy manufacturers and their customers, and that no government approvals are possible or appropriate. This remains our position with respect to the legal status of the Part 572 dummy specification.; We will be glad to answer any questions of interpretation of Part 57 or other National Highway Traffic Safety Administration regulations. We will also give full consideration and a timely response to any petitions for changes in these regulations, in accordance with the statutory requirements of the 1974 Amendments to the Act. I invite you to submit any such questions or petitions on matters of interest to you.; Sincerely, James B. Gregory, Administrator