Interpretation ID: nht75-2.38

DATE: 08/11/75

FROM: AUTHOR UNAVAILABLE; R. B. Dyson; NHTSA

TO: The Budd Company

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of July 8, 1975, asking which standards might be affected by the mounting of a tail lamp in the elastic skin of a bumper.

Motor Vehicle Safety Standard No. 215, Exterior Protection, prescribes barrier and pendulum impact tests to which vehicles must be subjected without incurring certain types of damage. Included in the list of safety systems that must remain undamaged are lamps and reflective devices. S5.3.1 of Standard 215 states that each lamp or reflective device, except license plate lamps, must remain free of cracks and comply with the applicable visibility requirements of S4.3.1.1 of Standard No. 108, Lamps, Reflective Devices, and Associated Equipment.

The manufacturer should be aware that placement of a tail lamp in the elastic skin of a bumper might expose it to damage during Standard 215 compliance testing.

For your information, I have enclosed copies of the current Standard No. 215, the proposed Part 580 bumper damageability standard, and Standard No. 108.