Interpretation ID: aiam2774
Jr.
Volkswagen of America
475 L'Enfant Plaza
S.W.
Suite 2450
Washington
DC 20024;
Dear Mr. Hutchinson: This responds to your January 30, 1978, request for confirmation tha no requirement in S 581.5(c) of the Part 581 *Bumper Standard* limits damage to the supporting ribs inside a plastic bumper face bar component or to the bumper face bar reinforcement component of the bumper system that lies within and reinforces the bumper face bar itself. You also requested confirmation that bumper 'end cuffs' are part of a bumper face bar if they are impacted by the impact ridge of the pendulum test device.; As we understand your description of the bumper reinforcement, it i not a bumper face bar, an exterior surface of the vehicle, or one of the other regulated portions of the vehicle. Therefore, it would not be regulated by the standard.; Internal deformation or cracking of the bumper face bar component doe not violate the provisions of S 581.5(3) as long as the dent and set requirements of (c)(11) are otherwise met.; 'Bumper face bar' is defined in S4 as 'any component of the bumpe system that contacts the impact ridge of the pendulum test device.' Protective ends or cuffs on a steel bumper face bar are considered components of the bumper system and, if contacted by the impact ridge of the pendulum test device, qualify under the definition as a portion of the bumper face bar subject to the same damageability limits as the rest of the bumper face bar.; Sincerely, Joseph J. Levin, Jr., Chief Counsel