Interpretation ID: aiam1097
Director
Automotive Safety Engineering
Environmental Activities Staff
General Motors Corporation
General Motors Technical Center
Warren
MI 48090;
Dear Mr. Lundstrom: This is in reply to your letter of December 14, 1972, concerning th effect of Standard 215 on optional bumper guards. You have asked us to interpret the standard as permitting the removal of such guards during the pendulum tests.; We do not consider the standard as it presently stands to permit bumpe guards or other attachments (other than trailer hitches for which direct relief is given in S6.1.5) to be removed for testing. The standard requires the vehicle to meet the standard in its as-delivered condition, without any reference to bumpers or other specific components. Considering your inquiry as a petition for rulemaking to allow bumper guards that do not conform to the standard, we find such rulemaking action inadvisable on the basis of our present information, for the following reasons.; 1. There is no definition of 'bumper guard', and it would be difficul to formulate one with precision, so that the standard would be vague and unobjective as to what is permitted or prohibited.; 2. If the bumper guard were undefined, it could be hostile both t pedestrians and to other vehicles. Yet if it were defined, it is difficult to see how a configuration significantly different from that required by Standard 215 could be justified.; 3. Standard 215 was carefully drafted, with a great deal of usefu exchange of ideas between industry, other members of the public, and the NHTSA, to require a front and rear configuration that would provide a reasonably uniform protective surface, and good inter-vehicle matching, without an unreasonable cost penalty. To allow these surfaces to be covered with an undefined 'bumper guard' would destroy the uniformity that is at the heart of the standard.; 4. We have no concrete evidence at this time that a substantia aftermarket in bumper guards would spring up. With bumpers that are protective and uniform in height, it might well be that the public will resist altering their vehicles at extra expense to degrade the uniformity of the vehicles as manufactured.; On the basis of the information that we presently have, therefore, you request for the exemption of optional bumper guards from the requirements of Standard 215 is denied. You are welcome, however, to submit further detailed information as to the costs and benefits that would be involved in such an action.; Sincerely, James E. Wilson, Acting Administrator