Interpretation ID: 11393JEG

Dr. Aled Williams
Vehicle Engineering
Transport Research Laboratory
Old Wokingham Road
Crowthorne, Berkshire RG45 6AU
United Kingdom

Dear Dr. Williams:

This responds to your letter concerning shoes for the Hybrid III dummy. I apologize for the delay in our response. You noted that Federal Motor Vehicle Safety Standard (FMVSS) No. 208 references certain drawing numbers for the shoe specification, and asked whether there are shoes available in the U.S. which conform to these specifications. You also asked us two additional questions in the event that such shoes are not available: What shoes does NHTSA use for compliance testing, and what are the essential characteristics that should be identified for the shoes used for the Hybrid III dummy. Your questions are addressed below.

By way of background, section S8.1.9.2 of FMVSS 208 specifies, for the Hybrid III dummy, that "(a) size 11EE shoe specified in drawings 78051-294 (left) and 78051-295 (right) or their equivalents is placed on each foot of the test dummy." These drawings specify gray suede leather safety shoes, size 11EE, made by Lehigh Safety Shoe Co, "or equivalent." Lehigh Safety Shoe Co. no longer makes this particular shoe.

Question 1: Are there shoes available in the U.S. which conform to Standard 208's specifications?

S8.1.9.2 specifies the use of the Lehigh shoe Aor equivalent.@ Although the Lehigh shoe is not available, we use an "equivalent" shoe, as further explained in answer to Question 2, below.

Question 2: What shoes does NHTSA use for compliance testing?

NHTSA=s Laboratory Test Procedure manual for FMVSS 208 addresses your question. Section 12.9 of the manual specifies, for both Hybrid II and Hybrid III dummies, that "(e)ach foot of the dummy shall be equipped with a size 11EE shoe which meets the configuration, size, sole, and heel thickness specifications of MIL-S-13192 and weighs 1.05 pounds to 1.45 pounds."

Question 3: What are the essential characteristics that should be identified for the shoes used for the Hybrid III dummy.

The dictionary defines "equivalent" as "equal in value, measure, force, effect, significance, etc." In determining whether a particular shoe is equivalent to the one specified in FMVSS 208, we consider whether use of the shoe would have any effect on the dummy readings that are used to calculate the standard's injury criteria. We have found the MIL-S-13192 shoe to be satisfactory in testing for the current injury criteria of FMVSS 208.

I also note that the Society of Automotive Engineers is in the process of developing a new shoe specification for the Hybrid III dummy. After that organization completes its work, NHTSA may decide whether to incorporate that specification in FMVSS 208.

I hope this information is helpful. If you have any further questions, please feel free to call Edward Glancy of my staff at (202) 366-2992.

Sincerely,

Samuel J. Dubbin Chief Counsel

Enclosure ref:208#572 d:3/29/96