Interpretation ID: 11618.MLV

Philip E. Brown, General Manager Europe
First Technology Safety Systems
European Office
2, Columbus Drive
Summit Ave., Southwood
Farnborough, Hants GU14 ONZ
England

Dear Mr. Brown:

This responds to your letter of February 23, 1996, concerning the pants for the Hybrid III dummy. You asked whether the pants should be below- or above-the- knee.

Section S8.1.9.2 of Standard No. 208, Occupant Crash Protection, states that the Hybrid III dummy shall be Aclothed in formfitting cotton stretch garments with . . . midcalf length pants.@ However, it has come to our attention that it is common practice for manufacturers and for the National Highway Traffic Safety Administration (NHTSA) contractors performing compliance tests to either cut off the pants above the dummy knees or to roll the pants up above the knees. Therefore, to update Standard No. 208 to reflect current practices, NHTSA will be publishing a notice of proposed rulemaking to amend Standard No. 208 to specify that the pants on the test dummies are to be above the knee. NHTSA will continue using above-the-knee pants in the interim, and we assume manufacturers will do so also.

I hope this information has been helpful. If you have other questions or need some additional information, please contact Mary Versailles of my staff at this address or by phone at (202) 366-2992.

Sincerely,

Samuel J. Dubbin Chief Counsel

ref:208 d:6/14/96