Interpretation ID: aiam3214
Fiat Motors of North America
Parklane Towers West
Suite 1210
Dearborn
MI 48126;
Dear Mr. Fozzati: This is in response to your letter of November 15, 1979, requestin that paragraph S8.1.9 of Safety Standard No. 208, *Occupant Crash Protection*, be corrected to change the phrase 'size 11EE shoe' to 'size 11E shoe.' I am sorry for the delay in this response.; Size '11EE' shoes are specified in the standard to allow eas application of the shoes to the test dummy's feet. If the feet of the dummy are of the absolute maximum width allowed by the standard, some size '11E' shoes are very difficult to apply. However, the agency does not believe that use of either '11E' or '11EE' shoes will cause a variation in test results. Therefore, a manufacturer should be safe in using either size. Mr. Radovich was incorrect in his statement that size '11EE' shoes are not available on the market. Size '11EE' shoes can be obtained from the Freeman Shoe Company, the Bostonian Shoe Company and other companies by special order.; For the reason stated above, we do not anticipate amending the standar to specify that shoe size should be '11E'. However, if you have any data or other information indicating that test results can vary between use of size '11E' or size '11EE' shoes, we would certainly appreciate seeing the data.; Sincerely, Frank Berndt, Chief Counsel