Interpretation ID: 77-3.45

TYPE: INTERPRETATION-NHTSA

DATE: 08/04/77

FROM: AUTHOR UNAVAILABLE; Joseph J. Levin Jr.; NHTSA

TO: Alderson Research Laboratories Inc.

TITLE: FMVSR INTERPRETATION

TEXT: This responds to Alderson Research Laboratory's July 15, 1977, request for confirmation that Part 572, Anthropomorphic Test Dummy (49 CFR 572), neither requires nor prohibits venting of the abdominal insert specified in drawing No. ATD 3250-2. The agency proposed the addition of leak test specifications to the drawing in August 1975 (40 CFR 33462, August 5, 1975) but they were not made final (42 CFR 7148, February 7, 1977).

Your interpretation that Part 572 neither requires nor prohibits venting of the abdominal insert is correct. The language you cite from the preamble to our February 1977 rulemaking is misleading in suggesting the requirement for venting. The agency more clearly described the requirement in its most recent amendment of Part 572 (42 FR 34299, July 5, 1977), stating that the Part does not "specify an abdominal sealing specification." Agency testing demonstrated conforming results both with and without venting (DOT HS-020875) and sees no reason to control this aspect of dummy design.

SINCERELY,

ALDERSON RESEARCH LABORATORIES, INC.

July 15, 1977

Stanley Backaitis National Highway Traffic Safety Administration Office of Crashworthiness

Subject: Abdominal Inserts, 49CFR Part 572

Notice 04 of Docket 73-8 finalized rulemaking on the Part 572 Anthropomorphic Test Dummy, and, in so doing, retracted an earlier proposed change which would have required the abdominal insert of the dummy to be sealed and leak free. It is our clear understanding that this retraction merely reverted the insert back to its original form, which imposed no rigid requirements for either sealing or venting of this component. Indeed, the original specifications for this insert were virtually universally interpreted as leaving the question of venting or not venting entirely discretionary as long as the Part 572 component calibration tests were satisfied.

In conversation with several of our customers, we are informed that widespread opinion exists that notice 04 now absolutely requires the abdominal insert to be vented, despite the fact that the manufacturing drawing (ATD-3250-2) for this component now, as before, provides no definition for any breathing vent. We think that the reason for this belief is based on the wording of the preamble discussion of Notice 04 which states ". . .the leak test has been removed from the drawings and the vent is retained." We respectfully suggest that the addition of the words " as an option" at the end of this phrase would have reenforced the clarity of the retraction of the proposed sealed only specification. We are, accordingly, requesting from the NHTSA a firm declarative statement as to whether or not the NHTSA's current specifications still permit discretionary venting or sealing of the abdominal insert.

Robert Rubenstein Chief Engineer

HUMANOID SYSTEMS DIVISION OF HUMANETICS, INC.

June 3, 1977

Stanley Backaitis NHTSA

We are in the process of revising our test equipment to take into account the new revision of the Part 572 specifications. In this connection, we want to inquire about the added provision that the neck pendulum "shall not reverse direction until T = 123 ms."

We would presume that this means that the minimum time for reversal should be 123 ms, since otherwise the variability of the honeycomb would make this an impossible standard to meet. Can you confirm our interpretation, or if we are in error, could you give us a tolerance on the 123 ms?

Samuel W. Alderson President