Interpretation ID: nht93-3.38

DATE: May 6, 1993

FROM: John Womack -- Acting Chief Counsel, U.S. Department of Transportation, NHTSA

TO: Jim Keizer

TITLE: None

ATTACHMT: Attached to letter dated 4-13-93 from Jim Keizer to NHTSA (OCC 8557); Also attached to letter dated 3-26-93 from John Womack to Jay Lee (Std. 208); Also attached to letter dated 3-26-93 from John Womack to Steven C. Friedman (Std. 208); Also attached to letter dated 6-11-91 from Paul Jackson Rice to Stephen Mamakas (Std. 208); Also attached to letter dated 5-13-91 from Paul Jackson Rice to Stephen Mamakas (Std. 208); Also attached to letter dated 1-19-90 from Stephen P. Wood to Linda L. Conrad (Std. 208)

TEXT: This responds to your letter of April 13, 1993, requesting information on the legal responsibilities of businesses that repack or replace air bags in automobiles.

I am enclosing copies of five letters which address various issues related to replacement or repair of air bags. The January 19, 1990, letter to Ms. Linda L. Conrad addresses the issue of possible legal obligations to repair a deployed air bag following a collision. The May 13, 1991, and June 11, 1991, letters to Mr. Stephen Mamakas address issues specifically related to the repair of deployed air bags. The March 26, 1993, letters to Mr. Steven C. Friedman and Mr. Jay Lee address issues related to retrofit or replacement air bags.

I have also enclosed an information sheet that identifies relevant Federal statutes and NHTSA standards and regulations affecting motor vehicle and motor vehicle equipment manufacturers, and explains how to obtain copies of these materials.

I hope you find this information helpful. If you have any other questions, please contact Mary Versailles of my staff at this address or by phone at (202) 366-2992.