Interpretation ID: aiam2699
Nissan Motor Co.
Ltd.
P.O. Box 1606
560 Sylvan Avenue
Englewood Cliffs
NJ 07632;
Dear Mr. Iinuma: This is in response to your letter of October 11, 1977, askin questions regarding application of the set and dent limitations contained in Part 581, *Bumper Standard*.; Your letter contained a series of diagrams about which questions on th applicability of the bumper damage criteria were asked. The questions are answered in the order in which they were posed.; 1. A total deformation of 9/8-inch is allowed only at the points on th bumper which actually come into contact with the impact ridge of the pendulum test device or the barrier face. All other bumper surfaces are limited to deformation no greater than 3/4-inch set.; 2. The crack illustrated in Question 2 would not be a dent as describe in S 581.5(c)(11)(ii). A crack that did not entail a measurable separation of the exterior surface of the bumper face bar, would not constitute a deviation in the contour of that component.; 3. Dimension A measures the change in contour and should be used t determine the size of the dent at the point of contact with the impact ridge of the pendulum test device or the barrier face.; 4. The straight line to measure the dent would be that labeled 'D since it connects the bumper contours adjoining the area of contact with the impact ridge of the pendulum test device. The size of the dent would be the distance from the original contour surface to the final deformation surface at the point of contact with the impact ridge.; 5. Dimension B identifies the amount of bumper set since it marks th distance of maximum change in the position of the bumper face bar relative to the vehicle frame.; 6. Since dents only occur at the point of contact with the impact ridg of the pendulum test device or the barrier face, the deformations described in the illustrations would be set.; 7. Since the deformation is not at the point of contact with either th impact ridge of the pendulum test device or the barrier face, it is set.; 8. If the operating force initially required to open the hood followin impact is within a range that permits operation by the normal universe of drivers, unaided by any tools, it would probably not be considered a noncompliance under the standard.; Sincerely, Joseph J. Levin, Jr., Chief Counsel