Interpretation ID: aiam1858
Technical External Relations
Van Doorne's Personenautofabriek DAF B.V.
Postbus: 1015
Geldropseweg 303
HOLLAND;
Dear Mr. Delen: This is in response to your letter of March 17, 1975, asking whethe the pendulum test device sensors described in section S5.3.7 of the March 12, 1975, notice proposing to amend the Federal bumper standard must be installed for compliance testing if you can prove that no part of the test device, other than the impact ridge, will contact the vehicle.; Under the assumption of your letter, the force and pressure measurin sensors would not need to be installed on planes A and B of the pendulum test device during your compliance testing. A manufacturer is only obligated to exercise due care in assuring himself that his product is capable of meeting the performance requirements of applicable standards when tested in the manner prescribed. If a vehicle is constructed so that it does not touch planes A and B, there is no need to measure the force and pressure on those surfaces.; Yours truly, Richard B. Dyson, Assistant Chief Counsel