Interpretation ID: aiam2873
Staff
Safety
Nissan Motor Company
Ltd.
P.O. Box 1606
560 Sylvan Avenue
Englewood Cliffs
NJ 07632;
Dear Mr. Murakami'(sic) This is in response to your letter of August 30, 1978, concerning th application of the Part 581, *Bumper Standard*, pendulum test conditions to vehicles equipped with height control systems.; Part 581 requires that a vehicle meet the protective requirements o the standard when tested at unloaded vehicle weight, that is, without occupants or cargo and with maximum capacity of all fluids necessary for operation of the vehicle. There is no language in the pendulum test requirements of the standard which would limit their applicability to only the ignition-on or ignition-off situation or to the recommended driving position for normal roadways. The vehicle must be capable of meeting the pendulum test requirements at all stable bumper heights possible at unloaded vehicle weight.; Thus, in the situations described in Question 1 and 2 of your letter in which an automatic height control system is employed, the vehicle must comply with the pendulum test requirements in both the ignition-on and ignition-off positions, i.e., positions (1) and (2). In the situation where vehicle height can be controlled manually as described in Questions 3 and 4 of your letter, the vehicle must comply with the standard at all possible settings, i.e., positions (1), (2) and (3). The presence of a label cautioning against operation of the vehicle in other than the position recommended for normal conditions would not alter the manufacturer's responsibility for compliance. In the case of National Highway Traffic Safety Administration compliance testing (Question 5), the agency will conduct its pendulum tests with the vehicle in a stable situation at unloaded vehicle weight, but may test a particular vehicle in either the ignition-on or ignition-off condition.; Sincerely, Joseph J. Levin, Jr., Chief Counsel