Interpretation ID: aiam2649
37-A Haddon Road
Cranbury
NJ 08512;
Dear Mr. Karlan: This is in response to your letter of June 10, 1977, requesting advic as to how your bumper-attachable energy absorber can be tested in order to establish its efficacy.; As you probably know, the National Highway Traffic Safet Administration (NHTSA) has promulgated a bumper standard (49 CFR Part 581, *Bumper Standard*) that will, beginning September 1, 1978, prohibit damage to vehicle surfaces, other than the bumper, during 5 mph test impacts. Phase II of the standard, which goes into effect September 1, 1979, will prohibit any damage to the bumper that exceeds 3/8 inch dent and 3/4 inch set. Since manufacturers will be required to meet these levels of bumper performance, shock absorbers such as yours may be greatly needed.; The NHTSA does not specify any design characteristics in its standards Thus, manufacturers are permitted to choose whatever design they wish, as long as their vehicles are capable of meeting the performance criteria provided in the standard. Thus, I suggest that you communicate with the automobile manufacturers regarding use of your shock absorber.; The contracts to which you refer in your letter were for th development of total vehicles. I suggest you contact an independent laboratory for testing your energy absorber.; Sincerely, Joseph J. Levin, Jr., Chief Counsel