Interpretation ID: nht94-2.61

TYPE: INTERPRETATION-NHTSA

DATE: April 27, 1994

FROM: DEAN LAKHANI -- PRESIDENT, GEM MANUFACTURING CORPORATION

TO: OFFICE OF CHIEF COUNSEL -- NHTSA

TITLE: NONE

ATTACHMT: Attached to letter dated 8/3/94 from John Womack to Dean Lakhani (Std. 208)

TEXT: Dear Counselor,

Our company has been in business will over 50 years, manufacturing bumper guards for the passenger car, pickup truck and van industry. These products are used in our country and sometimes exported abroad. These products have over the years saved lot s of lives and a lot of money spent towards costs resulting out of collision damage.

There were several competitors in the days when all the auto vehicles had metal and five mile per hour crash bumpers. Now, it appears that (and we have been told by Ford and General Motors) we are the only bumper guard manufacturing company left in a ll the U.S. All the other bumper guards manufacturers have closed down because of lack of market for bumper guards.

Our primary market disappeared when the 2 1/2 mile collapsible plastic or fiberglass bumpers were approved. Now with the introduction of the air bags (Federal Motor Vehicle Standard # 208), our taxi-cab and police car markets are drying up.

General Motors and other auto manufacturers, it appears have advised consumers, taxi-cab and police fleet administrations that if a bumper guard or any other similar device is placed in front of the bumper, it would interfere with # 208 device (the ai r bag) and the car manufacturers guarantees or warranties would then be questionable. This has caused the consumers, taxi-cab and police car administrators enough concern so as to stop buying bumper guards from us. This has caused the taxi-cab bumper g uard market and the police car bumper guard market to reduce substantially and it is now literally drying up. We may be forced soon to close our doors.

2

We need your prompt assistance, your unequivocal opinion on the issue of whether the attachment of a bumper guard to the front bumper of a vehicle will interfere with Federal Motor Vehicle Standard # 208 devise (air bag device).

Sir/Madam, in our company, except for three employees, the next junior most employee has been with the company for 17 years and the 2 senior most employees have been with the business 43 years and 47 years, respectfully. By closing this business, bel ieve me, we will lose hands-on knowledge and talent that has been the backbone of our country's industrial might!

Please do help us. We are all praying for your prompt response.