Interpretation ID: aiam4375
Manager
Regulations and Compliance
Volvo Cars of North America
Rockleigh
NJ 07647;
Dear Mr. Shapiro: This responds to your letter concerning the Part 581 Bumper Standard You asked whether headlamp washer- wiper systems should be removed from a vehicle prior to testing. As discussed below, the answer to your question is yes.; By way of background information, the National Highway Traffic Safet Administration does not provide approvals of motor vehicles or motor vehicle equipment. Under the statutes administered by NHTSA, it is the responsibility of the manufacturer to ensure that its vehicles and equipment comply with applicable requirements.; Section 581.6 of the Bumper Standard specifies a number of condition which apply to the standard's impact tests. One of these conditions, set forth in paragraph (a)(5), is that '(t)railer hitches, license plate brackets, and headlamp washers are removed from the vehicle.' You stated that the standard was promulgated prior to the advent of headlamp washer-wiper systems, and suggested that the interpretation of 'headlamp washers' can be expanded to include headlamp washer-wiper systems. It is our opinion that for purposes of the Part 581 Bumper (sic) the term 'headlamp washers' is sufficiently broad to include headlamp washer-wiper systems.; Sincerely, Erika Z. Jones, Chief Counsel