Interpretation ID: aiam1710
House of Representatives
Washington
DC 20515;
Dear Mr. Downing: This is in response to your letter of November 25, 1974, requestin this agency's comments on correspondence from one of your constituents, Ms. Cathy Alligood, concerning Federal regulations regulating bumper height and tire location.; The NHTSA has promulgated no standards regulating the protrusion o tires outside of the vehicle fenders. There may, however, be a State requirement pertaining to this aspect of performance.; A standard does exist that relates to motor vehicle bumper systems (4 CFR Part 571.215, *Exterior Protection*). According to that standard all vehicles manufactured after September 1, 1973, must possess bumpers which meet a certain level of performance. One aspect of the standard assures a uniform bumper height since the vehicle must be capable of sustaining pendulum impacts (during compliance testing) at certain heights while incurring only limited damage. Bumpers which are located at heights above or below a certain level would not be capable of satisfying these specified damage criteria. We have determined that uniform bumper heights are an essential element to motor vehicle safety.; Responding to the issue raised by Ms. Alligood concerning th alteration of bumper heights, such alteration could occur if the vehicle was not thereby brought out of compliance with the bumper standard. If the alteration of the bumper height caused the vehicle no longer to comply with the standard and such alteration was accomplished by the manufacturer, distributor, dealer, or a motor vehicle repair business, a violation of S 108(a) (2) (A) would have occurred. If, however, the alteration was done after the first purchase of the vehicle for purposes other than resale by someone other than a manufacturer, distributor, dealer, or motor vehicle repair business, no violation would have occurred.; Yours truly, Richard B. Dyson, Acting Chief Counsel