Interpretation ID: nht95-3.8

TYPE: INTERPRETATION-NHTSA

DATE: June 9, 1995

FROM: John Womack -- Acting Chief Counsel, NHTSA

TO: Don Bearden -- Director, Governmental Affairs, Subaru of America, Inc.

TITLE: NONE

ATTACHMT: ATTACHED TO 5/19/95 LETTER FROM DON BEARDEN TO JOHN WOMACK

TEXT: Dear Mr. Bearden:

This is in response to your letter of May 19, 1995, in which you state that Subaru of America, Inc. is considering the use of an optional rear bumper-mounted spare tire carrier on a future vehicle, and request this office to confirm your understanding th at the tire and carrier are to be removed before the vehicle is tested for compliance with the Bumper Standard, 49 CFR Part 581.

Your letter states that this equipment "would be mounted to the bumper beam and face bar." As your letter notes, bumper test conditions at 49 CFR 581.6(a)(5) specify that "[running] lights, fog lamps, and equipment mounted on the bumper face bar are remo ved from the vehicle if they are optional equipment." In light of this requirement, if the spare tire carrier your letter describes is only to be offered as optional equipment, it would have to be removed before the vehicle is tested for compliance with the Bumper Standard.

If you have any further questions regarding this matter, feel free to contact Coleman Sachs of my staff at the above address, or by telephone at (202) 366-5263.