Interpretation ID: aiam2235
Vice President
Engineering and Service
Mercedes- Benz of North America
Inc.
One Mercedes Drive
P. O. Box 350
Montvale
NJ 07645;
Dear Mr. Gerth: This is in response to your letter of January 26, 1976, concerning th applicability of the pendulum impact requirements of Standard No. 215, *Exterior Protection*, to vehicles that are capable of height adjustment through the suspension system controls.; You described in your letter a system on your 450SEL 6.9 liter mode which allows a driver to adjust the height of the vehicle with the suspension system controls. When the vehicle is in the elevated position, a red warning lamp in the instrument cluster is illuminated in order to alert the driver to the fact that the vehicle is not in its recommended driving position for normal road conditions. In addition, the owner's manual informs the driver that the vehicle should be operated in the raised position only when being driven on rough terrain.; Standard No. 215 requires that vehicles be capable of complying wit certain damage criteria when impacted at any height between 16 and 20 inches by a pendulum test device. Since the 450SEL is constructed in such a manner as to allow its operation at a range of heights, testing for compliance with the pendulum impact requirements must be conducted with the vehicle in all such positions.; There is no language in the standard which would limit it applicability to vehicles in only their recommended driving position for normal roadways. The range of heights available for operation must be addressed during compliance testing and the vehicle must satisfy the damage criteria at all levels. The warning light that is activated when the vehicle is in the raised position and the owner's manual warning that the vehicle should be operated in the raised position only when driving over rough terrain do not alter the responsibility of the manufacturer to assure vehicle compliance at all positions with the bumper pendulum requirements. The vehicle is capable of being driven at any and all times in the raised position and, therefore, must comply with the bumper standard's pendulum requirements.; Sincerely, Frank Berndt, Acting Chief Counsel