Interpretation ID: nht80-1.27
DATE: 03/07/80
FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA
TO: Fiat Motors of North America
TITLE: FMVSR INTERPRETATION
TEXT: This is in response to your letter of November 15, 1979, requesting that paragraph S8.1.9 of Safety Standard No. 208, Occupant Crash Protection, be corrected to change the phrase, "size 11EE shoe" to "size 11E shoe." I am sorry for the delay in this response.
Size "11EE" shoes are specified in the standard to allow easy application of the shoes to the test dummy's feet. If the feet of the dummy are of the absolute maximum width allowed by the standard, some size "11E" shoes are very difficult to apply. However, the agency does not believe that use of either "11E" or "11EE" shoes will cause a variation in test results. Therefore, a manufacturer should be safe in using either size. Mr. Radovich was incorrect in his statement that size "11EE" shoes are not available on the market. Size "11EE" shoes can be obtained from the Freeman Shoe Company, the Bostonian Shoe Company and other companies by special order.
For the reason stated above, we do not anticipate amending the standard to specify that shoe size should be "11E". However, if you have any data or other information indicating that test results can vary between use of size "11E" or size "11EE" shoes, we would certainly appreciate seeing the data.
Sincerely,
ATTACH.
November 15, 1979
Frank Berndt -- Chief Council, NHTSA
Dear Mr. Berndt,
As per my conversation with Mr. Radovich of your staff, I am requesting NHTSA to please correct FMVSS 208 para 8.1.9 as follows:
from: . . . with a size 11EE shoe . . .
to: . . . with a size 11E shoe . . .
Mr. Radovich agreed with me that this type of shoe is not available in the market and there is no explanation as to why NHTSA put 11EE in the standard.*
(*) type 11E is available from Freeman Shoe Co. in Wisconsin.
If you have any questions on the matter, please feel free to contact me, (313) 336-2400.
My best regards,
Aldo Fozzati -- FIAT RESEARCH & DEVELOPMENT, U.S.A. BRANCH