Interpretation ID: aiam3058
Volkswagen of America
7111 E. Eleven Mile Road
Warren
MI 48090;
Dear Mr. Haenchen: This is in response to your letter of March 19, 1979, regarding th photographic procedures, announced in Docket 73-19, Notice 24 (43 FR 40229, September 11, 1978), to be used by the National Highway Traffic Safety Administration (NHTSA) in evaluating shielding panel damage in compliance testing for the Part 581 *Bumper Standard* (49 CFR Part 581). You ask where the camera is located when taking the 45 degree angle photograph specified in Notice 24 under the heading Camera Position. You also ask where the three photoflood lamps specified in Notice 24 under the heading Illumination are positioned.; Where the plan of the shielding panel area under examination i nominally horizontal, NHTSA positions the camera and lamps relative to the vertical reference line running through the center of the suspect area. Where the plane of the shielding panel area is nominally vertical and perpendicular to the longitudinal center line of the vehicle, the camera and lamps will be positioned relative to the horizontal reference line running through the center of the suspect area, parallel to the vehicle's longitudinal center line. Where the plane of the suspect area is nominally vertical and parallel to the longitudinal center line of the vehicle, the camera and lamps are positioned relative to the horizontal reference line running through the center of the suspect area, perpendicular to the vehicle's longitudinal center line.; In taking the 90 degree angle photograph, NHTSA positions the camera o the reference line so that the foremost point of the camera lens is six feet from the point at which the reference line intersects the surface of the suspect area (point S). In taking the 45 degree angle photograph, NHTSA positions the camera on a line which intersects the reference line at a 45 degree angle at point S, and which lies in a vertical plane containing the reference line. Where the reference line is vertical, the camera is positioned on a line which lies in a plane parallel to the vehicle's longitudinal center line. The camera is positioned so that the foremost point of the camera lens is six feet from point S. A camera position is chosen which provides an unobstructed view of the suspect area.; The two main photoflood lamps are positioned facing the exterio surface of the suspect area with the filament of each lamp ten feet from point S. Except where the reference line is vertical, the two main lamps are positioned in the horizontal plane containing point S, on opposite sides of the vertical plane containing the reference line, so that the lines connecting the lamp filaments with point S form a 45 degree angle with the reference line.; Where the reference line is vertical, the two main lamps are positione in the vertical plane containing point S which is perpendicular to the vehicle's longitudinal center line. The lamps are positioned on opposite sides of the vertical plane containing point S which is parallel to the vehicle's longitudinal center line, so that the lines connecting the lamp filaments with point S form 45 degree angles with the reference line.; NHTSA has determined that the third photoflood lamp described in Notic 24, to be employed for fill-in lighting, is unnecessary and this lamp is not used by the agency.; Sincerely, Frank Berndt, Chief Counsel