Interpretation ID: nht87-2.83

TYPE: INTERPRETATION-NHTSA

DATE: 08/31/87 EST

FROM: ERIKA Z. JONES -- NHTSA CHIEF COUNSEL

TO: WILLIAM SHAPIRO -- MANAGER, REGULATIONS AND COMPLIANCE-VOLVO

TITLE: NONE

ATTACHMT: JULY 9, 1987 LETTER FROM SHAPIRO TO JONES IS ATTACHED

TEXT: This responds to your letter concerning the Part 581 Bumper Standard. You asked whether headlamp washer-wiper systems should be removed from a vehicle prior to testing. As discussed below, the answer to your question is yes.

By way of background information, the National Highway Traffic Safety Administration does not provide approvals of motor vehicles or motor vehicle equipment. Under the statutes administered by NHTSA, it is the responsibility of the manufacturer to ensur e that its vehicles and equipment comply with applicable requirements.

Section 581.6 of the Bumper Standard specifies a number of conditions which apply to the standard's impact tests. One of these conditions, set forth in paragraph (a)(5), is that "(t)railer hitches, license plate brackets, and headlamp washers are remove d from the vehicle." You stated that the standard was promulgated prior to the advent of headlamp washer-wiper systems, and suggested that the interpretation of "headlamp washers" can be expanded to include headlamp washer-wiper systems. It is our opini on that for purposes of the Part 581 Bumper the term "headlamp washers" is sufficiently broad to include headlamp washer-wiper systems.