Interpretation ID: nht95-2.87

TYPE: INTERPRETATION-NHTSA

DATE: May 19, 1995

FROM: Don Bearden -- Director, Governmental Affairs

TO: John Womack -- Acting Chief Counsel, NHTSA

TITLE: Interpretation of 49 CFR Part 581, Bumper Standard

ATTACHMT: ATTACHED TO 6/9/95 LETTER FROM JOHN WOMACK TO DON BEARDEN (A43; PART 581)

TEXT: Dear Mr. Womack:

Subaru of America, Inc. is considering the use of an optional rear bumper-mounted spare tire carrier on a future vehicle as shown on the attached sketch. All trim levels of this vehicle would be offered both with and without the optional rear spare t ire carrier. (For vehicles without the optional external carrier, the spare tire would be carried inside the vehicle). At this time, we can only estimate the sales appeal of this option, but project that it will be specified for far less than 50% of th e car line.

The bumper test conditions contained in 49 CFR @ 581.6(5) specify that "[running] lights, fog lamps, and equipment mounted on the bumper face bar are removed from the vehicle if they are optional equipment." (Emphasis added.)

Since the Subaru optional spare tire carrier would be mounted to the bumper beam and face bar, we understand that the tire and carrier would be removed from the vehicle prior to the conducting of the Part 581 bumper test.

We would appreciate your confirmation of our interpretation.

Thank you for your assistance. Should you or your staff have any questions concerning this request, please contact me at (609) 488-8644

Enclosure

Rear spare tire carrier

without equipment with equipment

(Graphics omitted.)