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Interpretation ID: aiam2642

Mr. Robert Rubenstein, Chief Engineer, Alderson Research Laboratories, Inc., 390 Ludlow Street, Stamford, CT 06904; Mr. Robert Rubenstein
Chief Engineer
Alderson Research Laboratories
Inc.
390 Ludlow Street
Stamford
CT 06904;

Dear Mr. Rubinstein (sic): This responds to Alderson Research Laboratory's July 15, 1977, reques 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 prohibit 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, Joseph J. Levin, Jr., Chief Counsel