Interpretation ID: nht87-2.44

TYPE: INTERPRETATION-NHTSA

DATE: JULY 9, 1987

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

TO: ERIKA Z. JONES -- NHTSA CHIEF COUNSEL

TITLE: PART 581; BUMPER STANDARD DAMAGEABILITY REQUIREMENTS - REQUEST FOR INTERPRETATION

ATTACHMT: ATTACHED TO AUGUST 31, 1987 LETTER FROM JONES TO SHAPIRO

TEXT: In Part 581 the performance requirements for vehicle bumpers is set forth. Section 581.6 describes the condition of the bumper for testing. Paragraph (a)(5) of this section allows for headlamp washers to be removed prior to the test. This standard was promulgated prior to the advent of headlamp washer-wiper systems. Volvo believes the interpretation of "headlamp washers" can therefore be expanded to include headlamp washer-wiper systems so the standard can remain current with automotive technology.

We look forward to hearing from you on this matter. If you have any questions, please don't hesitate to contact me.