Interpretation ID: 581interpretation

Mr. Kenneth M. Bush
Regulations Manager
American Suzuki Motor Corporation
3251 E. Imperial Highway
Brea, CA 92821

Dear Mr. Bush:

This responds to your question of whether the front grille of a Suzuki passenger car qualifies as a bumper face bar component under 49 C.F.R. Part 581. The answer to your question is no, the front grille does not qualify as a component of the bumper face bar.

The purpose of the bumper standard, as set forth under Section 581.2, is to reduce the physical damage to the front and rear ends of passenger motor vehicles from low speed collisions. To accomplish this purpose, Part 581 requires the vehicle to withstand prescribed pendulum and barrier tests. Vehicles must experience no damage to vehicle exterior surfaces, and only limited damage to the bumper face bar, and the components and associated fasteners that directly attach the bumper face bar to the chassis frame. Section 581.4 defines the bumper face bar as any component of the bumper system that contacts the impact ridge of the pendulum test device. See Figures 1 and 2 of Part 581.

In an interpretive Federal Register notice that followed the publication of the rule, we addressed the application of the rule to bumper face bars and attached components. We explained that components must be examined on a case-by-case basis to determine whether they constitute components of the bumper system. We looked to the function of the component and recognized that some components could not qualify as components of the bumper system, even if contacted by the impact ridge of the pendulum or barrier. For example, "illumination devices, e.g., fog lamps and directional signals, are not associated with the bumper systems function and could not qualify as components of the bumper system, even if contacted by the pendulum test device or barrier." 43 Fed. Reg. 40229, 40230 (Sept. 11, 1978). However "other components could be considered components of the bumper system, depending on their application in a particular vehicle design." Id.For example a grille, which is generally associated with the body of the vehicle, "could perform a protective function as a component of a bumper system in a soft-face configuration, and could therefore qualify as a component of the bumper system." Id.

After reviewing your submitted materials, it appears that the Suzuki front grille is not a component of the bumper system. First, the grille appears to be a separate part that can be installed and removed independent of the front bumper. It is not an integral part of the bumper system. Second, the grille does not appear to be associated with the bumper systems function, namely performing a protective function of reducing the physical damage to the vehicle.

If you have any questions or concerns about this interpretation, please contact Raymond Woo at the Office of Chief Counsel at 202-366-5263.

Sincerely,

Jacqueline Glassman
Chief Counsel

ref:581
d.3/9/04