Interpretation ID: nht93-4.39

DATE: June 19, 1993

FROM: Ray M. Miyamoto

TO: Public Community Strategy, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 7/29/93 from John Womack to Ray M. Miyamoto (A41; Std. 208)

TEXT:

I would like to know if I can have my own business retrofitting older cars with air bags. I would like to be subject to the same rules and regulations as men who service brakes. I would emphasize in my advertising and all literature that seat belts should also be worn (just as the NHTSA emphasizes).

I would optionally retrofit cars of the same make and model, but would consider others if the retrofitting was not to complex or costly. There should be a way (and I'm sure there is) to pre-test each retrofit by deploying and (restuffing) or refitting the air bag and retrofitted equipment for about 20 to 50 deployments. That is, to trigger the sensors without any damage to the vehicle. Possibly I could test each retrofit by applying the same PSI that it would take to deploy it. (There is body and fender and/or construction equipment that can apply the same PSI as in a crash to test air bags.) Liability should be limited to replacement. Only in cases of poor workmanship, and/or gross incompatibility between the retrofit and the car, and/or negligence should I or any other retrofit serviceman be subject to liability.

Such retrofits would be a boon to the drivers of many older vehicles who don't have the funds or means to afford newer air bag equipped cars.

Also, in regard to testing, the bumper of the newer air bag equipped car could be retrofitted to the older vehicle if this would ease the deployment of the air bag in a normal manner (through the sensors) if the older car's bumper was found to block the sensors in any way or make it more difficult for air bag deployment.

There should be room for some compromise here. I don't think it is technically impossible to retrofit older cars with air bags. (And it is technically feasible.) Moreover, to deny people with older cars the right to have air bags, would mean injury and more needless deaths on our highways.

There should be a way for retrofit business (once government approval is given) to be tested by state or local auto safety inspection stations. It is not technically impossible to refit an air bag after a crash by replacing any or all of the following:

1) the air bag 2) sensors 3) wires and terminals 4) deployment canisters or cylinders 4) steering column 5) bumper 6) any other parts, such as a computer, and/or a motor(s).

If brakes can be tested, why not air bags? If an ABS can be tested, why not air bags? To give approval to retrofit businesses would break the monopoly new car manufacturers have on air bags and would lower prices on air bags, not to mention the thousands of lives saved as a result of the greater availability of air bags.

The opposition I have encountered regarding retrofitting of air bags has been without any logical basis. But I am open to any factual, logical and safe argument.

PS J.C. Whitney has a retrofit kit for anti-lock braking systems. So why not a kit for air bags? (as long as they're tested and inspected the ways I mentioned earlier). Moreover, how do you, the NHTSA and the new car manufacturers know that every air bag installed in a new car is safe? By pre-testing and/or inspecting, right? Retrofitting could be done in the SAME way.