Interpretation ID: Tunick telltale 001515

Mr. Lance Tunick

Vehicle Services Consulting, Inc.

PO Box 23078

Santa Fe, NM 87502-3078

Dear Mr. Tunick:

This responds to your letter in which you ask if a telltale for an air bag on-off switch may be located on the interior rearview mirror structure. As explained below, an air bag on-off switch telltale may be located in an area as you described so long as it complies with the applicable provisions of Federal Motor Vehicle Safety Standard (FMVSS) No. 208, Occupant Crash Protection.

On May 23, 1995, the agency amended FMVSS No. 208 in order to permit vehicle manufacturers to install a manual device that motorists can use to deactivate the front outboard passenger air bag in vehicles in which infant restraints can be used in the front seat only (60 FR 27233). The affected vehicles are passenger cars and light trucks unable to accommodate typical rear-facing infant restraints in a rear seat. If a manufacturer installs such an on-off switch, FMVSS No. 208 requires the manufacturer to provide a telltale to alert vehicle occupants when a front outboard passenger air bag is switched off.

In your letter, you asked if a telltale is permitted to be located on the interior rearview mirror structure if the specific criteria set forth in S4.5.4.3 of FMVSS No. 208 are met. You also requested a clarification of a previous interpretation letter to Mr. Ottar Cato Olsen in which the agency stated that an air bag on-off switch telltale must be located on the dashboard (November 5, 1997).

As originally adopted in 1995, S4.5.4.3 required an air bag on-off switch telltale to be located on the dashboard (60 FR 27233). However, the agency amended that requirement on January 14, 1999 (64 FR 2446; enclosed). The agency determined that eliminating the requirement for a telltale to be on the dashboard provides vehicle manufacturers greater flexibility regarding its location. We also determined that this flexibility would not result in a loss of safety.

Under the current FMVSS No. 208, S4.5.4.3 requires that:

A[n air bag on-off switch] telltale light in the interior of the vehicle shall be illuminated whenever the passenger air bag is turned off by means of the on-off switch. The telltale shall be clearly visible to occupants of all front seating positions. Clearly visible means within the normal range of vision throughout normal driving operations. The telltale:

a)      Shall be yellow;

b)      Shall have the identifying words PASSENGER AIR BAG OFF or PASS AIR BAG OFF on the telltale or within 25 millimeters of the telltale;

c)      Shall remain illuminated for the entire time that the air bag is off;

d)      Shall not be illuminated at any time when the air bag is on; and,

e)      Shall not be combined with the readiness indicator required by S4.5.2 of this standard.[1]

(Emphasis added.) I note that among other things, the telltale must be clearly visible to occupants of all front seating positions. Therefore, a telltale located on the structure of an interior rearview mirror that complied with the requirements listed in S4.5.4.3 would be permitted.

If you have any further questions, please contact Mr. Chris Calamita of my staff, at (202) 366-2992.

Sincerely,

Stephen P. Wood

Acting Chief Counsel

Enclosure

ref:208

d/6/16/06