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Interpretation ID: aiam0883

Mr. John L. McLaughlin, Registrar, Department of Motor Vehicles, Division of Registration, P.O. Box 1319, Sacramento, CA 95806; Mr. John L. McLaughlin
Registrar
Department of Motor Vehicles
Division of Registration
P.O. Box 1319
Sacramento
CA 95806;

Dear Mr. McLaughlin: This is in reply to your letter of September 14, 1972, on the subjec of potential conflict between the California statute regulating passenger car bumpers and Federal Motor Vehicle Safety Standard No. 215, Exterior Protection.; On October 20, 1972, the President signed into law the Motor Vehicl Information and Cost Savings Act (P.L.92-513). One effect of this act will be to allow a State bumper standard that relates to property damage to coexist with a Federal safety standard if it is is not in conflict with' the Federal standard.; We do not find that there is a 'conflict' between the Californi statute and the Federal standard with respect to the language underlined in your letter. As a practical matter, the difference between the SAE J-850 test barrier specified by California and the fixed collision barrier specified in our standard is slight. Most test barriers will conform to the significant aspect of both specifications. This would not appear to be the degree of difference that could be termed a 'conflict' under the new Act.; Please advise us if you have further questions on this subject. Sincerely, Lawrence R. Schneider, Chief Counsel