Interpretation ID: nht94-1.12
TYPE: Interpretation-NHTSA
DATE: January 7, 1994
FROM: D. E. Dawkins -- Director - Vehicle Compliance and Safety Affairs, Chrysler Corporation
TO: John G. Womack -- Acting Chief Counsel, NHTSA
TITLE: Request for Interpretation Regarding Combined Sun Visor Air Bag Caution Label and Utility Vehicle Label
ATTACHMT: Attached to letter dated 3/21/94 from John Womack to Dale E. Dawkins (A42; Redbook; Std. 208)
TEXT:
Chrysler Corporation requests that the NHTSA affirm an interpretation of MVSS 208-Occupant Crash Protection, that would permit the sun visor air bag caution label required in S4.5.1(b) to be combined with the utility vehicle information sticker required by 49 CFR Part 575.105. We believe that the messages of these labels are equally important to the operator of the vehicle, and that they can be effectively displayed together on a common label.
We are aware that General Motors Corporation and Ford Motor Company have submitted petitions for reconsideration of the final rule of Docket 74-14; Notice 82, which amends MVSS 208, in part, to require the sun visor label containing certain air bag cauti ons. Both companies ask that the agency further amend the air bag visor label requirement to permit the continued location of the utility vehicle label on the visor.
We support those petitions, and ask that the agency grant them and proceed with the proposed amendments. However, we ask that the agency also confirm that the information from both labels may not only appear on the same sun visor, but may be incorporate d into a single label on a given surface of the sun visor. In our opinion, the messages are of equal significance to the safe operation of the vehicle and deserve equal and simultaneous presentation to the driver. If the agency cannot affirm that posit ion within the existing regulation, please consider this request as a petition for rulemaking to that end.
If there are questions about this request, please address them to Howard Willson of my staff at (810) 370-8563.