Interpretation ID: aiam1084
113 West Broadway
Gettysburg
PA 17325;
Dear Mr. Feldmann: Thank you for your letter of March 23, 1973, concerning Federal Moto Vehicle Safety Standard No. 215, Exterior Protection.; Your first concern is the fact that bumpers which comply with Standar No. 215 still permit damage to occur to the vehicle during low- speed impacts. This situation occurs because Standard No. 215, which initially became effective on September 1, 1972, was developed in accordance with the National Traffic and Motor Vehicle Safety Act of 1966. This Act provided the authority to develop standards to improve vehicle safety during collisions, not solely to reduce property damage. The authority to develop bumper standards primarily to reduce property damage, the Motor Vehicle Information and Cost Savings Act, became law on October 20, 1972. As the result of this new Act, we are in the process of developing standards which limit automobile damage in low-speed bumper impacts.; Secondly, you cite the mismatch problems that continue to exist amon passenger car bumpers. Commencing with 1974 model cars, Standard No. 215 specifies requirements directed at correcting the mismatch problems that cause damage to safety-related components during low-speed, car-to-car collisions. It establishes a uniform interfacing surface among all cars that reduces the likelihood of override, underride, and interlock, all of which are quite prevalent with existing bumper designs.; Thirdly, you express concern over the numerous collisions involvin damage to corners of vehicles. Standard No. 215 also specifies requirements for 1974 model cars that will provide improved corner protection. A copy of the standard is enclosed for your use.; Lastly, you indicate the availability of inexpensive energy absorbin devices that could be used to manage the low-speed crash forces. We are aware of these and other devices of this type, however, as you will note, Standard No. 215 specifies minimum performance only without specifying the equipment or configuration to be used. We feel that this approach encourages competitive innovation and promotes technological progress to achieve the desired performance at minimum cost to the consumer.; We appreciate receiving your comments and your interest in improvin motor vehicle safety.; Sincerely, Robert L. Carter, Associate Administrator, Motor Vehicl Programs;