Interpretation ID: aiam1795
Manager Customer Service
MacDermid Incorporated
526 Huntingdon Avenue
Waterbury
CT 06720;
Dear Mr. Toller: This is in response to your letter of January 22, 1975, commenting o the recent proposal by the National Highway Traffic Safety Administration (NHTSA) to reduce the performance requirements for motor vehicle bumpers.; Under current Federal requirements, a vehicle bumper must be capable o withstanding 5-mph longitudinal front and rear barrier and pendulum impacts without experiencing certain types of specified damage. A recent NHTSA study, however, indicated that due to inflation, increasing shortages of certain materials, and the weight and cost of current production bumpers, the costs imposed by implementation of the bumper standard may be exceeding the benefits to be derived therefrom.; The proposed reduction in the requirements to 2 1/2 mph front and rea barrier and pendulum impacts was viewed as a means of attaining a favorable cost-benefit ratio by permitting the removal of certain heavy bumper system components. Considerable interest has been manifested in the contents of the proposal. The NHTSA conducted a public hearing on February 18 and 19, 1975, in order to permit the presentation of views from all interested persons regarding the proposed revision of the bumper standard.; The comment period for the notice has been extended until March 3 1975, in order to allow additional time for submission of comments and enable a full review of all evidence presented.; The comments contained in your letter will be placed in the appropriat public docket and will be considered in the formulation of the final rule.; Yours truly, James C. Schultz, Acting Chief Counsel