Interpretation ID: aiam2591
329 Miller Court
Harrison OH 45030;
Dear Mr. Niehaus: This is in response to your letter of May 2, 1977, asking whethe Federal requirements specify that motor vehicle bumpers must be equipped with a rubber stripping.; Standard No. 215, *Exterior Protection*, is a motor vehicle safet standard promulgated by the National Highway Traffic Safety Administration. That standard requires that passenger cars be capable of undergoing 5 mph front and rear impacts without incurring damage to certain specified safety systems. Motor vehicle manufacturers are permitted to meet the performance level prescribed by Standard 215 in whatever manner they choose. Most, however, have elected to meet the requirements by improving the strength of the vehicle bumper system. Although a rubber bumper strip is not specifically required by the standard, a manufacturer may use such a component as a means of meeting the prescribed performance level.; All 1977 model year cars must be capable of meeting the requirements o Standard 215. This includes those which are equipped with an optional bumper system and those which are not.; If we can provide you with any further information, please let us know. Sincerely, Joseph J. Levin, Jr., Chief Counsel