Interpretation ID: aiam1956
President
Humanoid Systems
Division of Alderson Biotechnology Corporation
5250 El Segundo Boulevard
Hawthorne
CA 90250;
Dear Mr. Alderson: This is in response to your letter of May 30, 1975, to th Administrator.; Thank you for the offer to assist in the establishment of ne specifications for dummy skin and flesh components. Any procurement of such services would be awarded by competitive procurement, and I hope your company will participate in any such competition when solicited.; The NHTSA issued Part 572, in the form of a large number of dumm design and material specifications supplemented by some calibrating component tests, in order to specify the vehicle performance requirements of certain crash-test standards, such as Standard No. 203, as precisely and objectively as possible. Dummies are not regulated items and not ends in themselves, as S 572.3 states, the dummy specification 'does not in itself impose duties or liabilities on any person.' Thus, the dummy specification serves only as a means of informing the vehicle manufacturers how their vehicles must perform if and when tested by the government. There is no regulatory requirement either for 'certification' of dummies or their 'verification by an independent agency' or anyone else. It may be assumed that government testing will be carried out with dummies that conform to Part 572 as closely as possible. Vehicle manufacturers can ascertain that their vehicles will pass government tests by any means they choose. With this in view, it should be clear that any deviations from the Part 572 specifications are purely a matter of private negotiation and decisionmaking between the dummy manufacturers and their customers, and no governmental 'approvals' are possible or appropriate.; Any changes in Part 572 will of course be done through notice an opportunity for comment, and we expect and hope for your full participation in an administrative proceeding when it takes place.; Sincerely, Robert L. Carter, Associate Administrator, Motor Vehicl Programs;