Mr. Toshiyuki Aoki
Engineering Department
Sensor Technology Co., Ltd.
FAX: +81-299-59-6121

Dear Mr. Aoki:

This responds to your fax asking about the neck injury criteria specified in the alternative unbelted sled test requirements of Safety Standard No. 208, Occupant Crash Protection. I apologize for the delay in this response.

You note that S13.2 of the standard specifies that the neck injury criteria are "measured with the six axis load cell (ref: Denton drawing C-1709) that is mounted between the bottom of the skull and the top of the neck as shown in drawing 78051-218." You state that you do not understand the neck transducer position for the Hybrid III dummy from this quoted language and ask whether it means "upper neck transducer," not "lower neck transducer."

The language quoted above does mean "upper neck transducer." The terms load cell and transducer are synonymous. The upper neck transducer is located, as specified in S13.2, between the bottom of the skull and the top of the neck, and is shown in that position on drawing 78051-218. By contrast, the lower neck transducer for the Hybrid III dummy is located between the top of the thorax and the bottom of the neck. (Our regulations do not specify use of the lower neck transducer for testing under Standard No. 208.)

I hope this information is helpful. If you have any further legal questions, you may refer them to Edward Glancy of this office at (202) 366-2992. If you have any technical questions about how we use the Hybrid III dummy in our tests, you may contact Stan Backaitis of our Office of Safety Performance Standards at (202) 366-4912.

John Womack
Acting Chief Counsel