Interpretation ID: nht87-2.64

TYPE: INTERPRETATION-NHTSA

DATE: 08/10/87

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Mr. Thomas Baloga

TITLE: FMVSS INTERPRETATION

TEXT: Mr. Thomas Baloga Safety Engineering Mercedes-Benz of North America, Inc. P.O. Box 350 Montvale, NJ 07645

Dear Mr. Baloga:

Thank you for your letter of May 12, 1987, to Stephen Oesch of my staff concerning the requirements of Standard No. 208, Occupant Crash Protection. You asked the agency to confirm that the 36 millisecond time interval to be used in the calculation of the head injury criterion (HIC) applies both to the Part 572, Subpart B test dummy and to the Subpart E test dummy. This is to confirm that the 36 millisecond time interval should be used in the calculation of a HIC for both types of test dummies.

On October 17, 1986 (51 F2 37028), NHTSA published a final rule in the Federal Register amending Safety Standard No. 208, Occupant Crash Protection. One of the amendments modified the manner in which a HIC is calculated in the crash testing required by t he standard. That amendment referred to @6.2 as the provision of the standard containing the HIC requirement. Instead, the notice should have amended @6.1.2, which sets out the HIC calculation for the Part 572, Subpart B test dummy, and @6.2.2, which set s out the HIC calculation to be used with the new Part 572. Subpart E test dummy.. The agency will publish an amendment to adopt the necessary changes to @6.1.2 and @6.2.2 to make clear that the change to the calculation of the HIC criterion affects thos e two provisions.

If you need further information, please let me know.

Sincerely,

Erika Z. Jones Chief Counsel

Mr. Steve Oesch Legal Counsel Department of Transportation NHTSA 400 Seventh St., S.W. Washington, DC 20590

Subject: Docket 74-14, Notice 47 Concerning FMVSS 208 Published in the Federal Register October 17, 1986

Dear Mr. Oesch:

Confirming our telephone request of May 4, 1987, we would be most appreciative if NHTSA could acknowledge in writing that in the subject FR it was erroneously printed, on page 37033 paragraph @6.2, that for calculating HIC values, the 36 millisecond time interval applies only to the Part 572, Subpart E, Hybrid III test dummy.

A corrected Part 571.208 will, in the future, indicate that the 36 millisecond time interval for HIC calculation applies to using either a Hybrid III or a Part 572 Subpart B test dummy. Since a correction notice in the FR may be further delayed due to hi gher priorities, we are eager to obtain this confirmation as soon as practicable.

Thank you very much for your assistance.

Sincerely,

Thomas Baloga Safety Engineering (201) 573-2622