ID: nht95-1.100

TYPE: INTERPRETATION-NHTSA

DATE: March 14, 1995

FROM: Philip R. Recht -- Chief Counsel, NHTSA

TO: Alberto Negro -- Chief Executive Officer, Fiat Auto R&D U.S.A.

TITLE: None

ATTACHMT: ATTACHED TO 9/29/94 LETTER FROM ALBERTO NEGRO TO JOHN WOMACK (OCC 10403)

TEXT: This responds to your letter concerning 49 CFR Part 583, Automobile Parts Content Labeling. I apologize for the delay in our response. Section 583.5 (g) provides that "a manufacturer that produces a total of fewer than 1000 passenger motor vehicles in a model year" need not provide the U.S./Canadian Parts Content or Major Foreign Sources items on the vehicle label required by that regulation. You asked whether the 1000 unit threshold applies to the Alfa Romeo and Ferrari marques separately or collectiv ely, as those marques are both owned by Fiat S.p.A. You stated that Fiat S.p.A. is the stockholder of Fiat Auto S.p.A., which produces Alfa Romeo cars, and of Ferrari S.p.A. which produces Ferrari cars. As discussed below, the 1000 vehicle threshold ap plies to Alfa Romeo vehicles and Ferrari vehicles separately, since they are produced by different companies.

Part 583 incorporates the statutory definition of "manufacturer" (see section 583.4 (a) and 49 U.S.C. 32304 (a) (7)), which reads as follows:

"Manufacturer" means a person --

(A) engaged in manufacturing or assembling new passenger motor vehicles;

(B) importing new passenger motor vehicles for resale; or

(C) acting for and under the control of such a manufacturer, assembler, or importer in connection with the distribution of new passenger motor vehicles.

The term "person" is defined at section 583.4 (b) as "an individual, partnership, corporation, business trust, or any organized group of persons."

Under these definitions, both the European producer and the importer are considered manufacturers of Alfa Romeo and Ferrari passenger motor vehicles. Therefore, both the producer and the importer are subject to Part 583.

In applying section 583.5 (g) in the context of your question, we would focus on the European producer rather than the importer. This is because that section provides that "a manufacturer that produces a total of fewer than 1000 passenger motor vehicles in a model year" need not provide the U.S./Canadian Parts Content or Major Foreign Sources items on the vehicle label required by that regulation. Since Alfa Romeo vehicles and Ferrari vehicles are produced by different European companies, the 1000 vehi cle threshold applies to them separately. I note that, as discussed in the final rule preamble, only passenger vehicles manufactured for sale in the United States are counted toward the 1000 vehicle threshold.

This interpretation is limited to section 583.5(g). The statutory provisions for other programs administered by NHTSA have different purposes and different definitions of "manufacturer." Also, the CAFE statute has special provisions concerning manufactu rers that are within a control relationship. Therefore, this interpretation should not be applied outside the context of section 583.5(g).

I hope this information has been helpful. If you have any other questions or need some additional information in this area, please contact Edward Glancy of my staff at this address or by phone at (202) 366-2992.

ID: nht95-1.11

TYPE: INTERPRETATION-NHTSA

DATE: January 5, 1995

FROM: Philip R. Recht -- Chief Counsel, NHTSA

TO: Amin Ahmadi

TITLE: NONE

ATTACHMT: Attached to 8/15/94 letter from Amin Ahmadi to Office of Rule Making

TEXT: Dear Mr. Ahmadi:

This responds to your letter requesting that the Federal government require all motor vehicles to be equipped with your mirror, which you believe reduces blind spots. You state that part of your mirror is shaped at a straight angle while another part ha s a three to five degree outward variance. As explained below, this agency, the National Highway Traffic Safety Administration (NHTSA), does not believe it should require all vehicles to be equipped with your mirror. Nevertheless, NHTSA does not prohibi t you from marketing your mirror, provided the mirror complies with the Federal standard on rearview mirrors and other safety considerations are met.

Before I begin, I would like to reference a November 29, 1994 telephone conversation between you and Mr. Marvin Shaw of my staff, about your request for the information in your letter be treated as confidential. Mr. Shaw explained that letters requestin g interpretations of our Federal motor vehicle safety standards (FMVSSs) are public information. Nevertheless, he further explained that we would only include a general description of your mirror in our response. Accordingly, we will return your sketche s to you and make only the cover letter publicly available. You agreed that this would satisfy your concerns about not disclosing your design concepts.

By way of background information, Congress has authorized NHTSA to issue FMVSSs for new vehicles and new items of equipment. NHTSA, however, does not approve motor vehicles or motor vehicle equipment. Instead, the law establishes a "self-certification" process under which each manufacturer is responsible for certifying that its products meet all applicable safety standards. The following represents our opinion based on the facts provided in your letter.

NHTSA has issued FMVSS No. 111, Rearview Mirrors (49 CFR @ 571.111, copy enclosed), to set performance requirements for new vehicle mirrors. FMVSS No. 111 establishes performance and location requirements for the rearview mirrors in each new motor vehic le. Vehicle manufacturers must certify that each of their new vehicles complies with the applicable requirements in FMVSS No. 111. Vehicle manufacturers may install mirror systems that combine a portion of the mirror with a straight angle with a portion of the mirror that is at a slight variance, provided that the straight mirror portion by itself complies with the requirements in FMVSS No. 111 that are applicable to the vehicle on which the mirror system is installed.

Assuming that the straight mirror portion of your mirror system complies with the applicable requirements of FMVSS No. 111, vehicle manufacturers could install this new mirror system on their vehicles.

However, even though your mirror may be installed as original equipment, NHTSA does not agree with you that new vehicles should be required to be equipped with a mirror system that has a portion that is at a slight variance. As explained in the enclosed notice about convex mirrors, while a convex mirror reduces blind spots by increasing a driver's field of view, such mirror systems also "increase distortion and reduce a driver's depth perception and judgement about another vehicle's closing distance." Like the mirror referenced in that notice, your mirror has both potential advantages and disadvantages: it would increase the driver's field of view, but it would to some extent increase the potential for confusing the driver, since it combines two diffe rent orientations.

Please note that since FMVSS No. 111 applies to the completed new vehicle, it does not apply to mirrors sold and installed as aftermarket equipment. However, there are other Federal requirements that indirectly affect an aftermarket mirror system. Under NHTSA"S enabling statute, the agency considers the mirror to be an item of motor vehicle equipment. Manufacturers of motor vehicle equipment are subject to our statute's requirements concerning the recall and remedy of products with safety related defe cts. I have enclosed an information sheet that briefly describes those responsibilities. In the event that you or NHTSA determines that your product contains a safety-related defect, you would be responsible for notifying purchasers of the defective eq uipment and remedying the problem free of charge.

In addition, manufacturers, distributors, dealers, and motor vehicle repair businesses are subject to a provision in the law, which states: "No manufacturer, distributor, dealer, or motor vehicle repair business shall knowingly make inoperative . . . any device or element of design installed on or in a motor vehicle or item of motor vehicle equipment in compliance with an applicable Federal motor vehicle safety standard . . ." Based on our understanding of your mirror system, it appears that its install ation would not make inoperative compliance with the standard. Nevertheless, if the installation of your mirror system resulted in a vehicle no longer complying with FMVSS No. 111, then the manufacturer, distributor, dealer, or motor vehicle repair busi ness that replaced the complying mirror with a noncomplying system would have made inoperative a device (the mirror system) installed in the vehicle in compliance with FMVSS No. 111. The law specifies a civil penalty of up to $ 1000 for each violation o f the make inoperative provision.

This provision in the law does not establish any limitation on an individual vehicle owner's ability to modify his or her own vehicle. Under Federal law, individual owners can install any mirror system they desire on their own vehicles, regardless of wh ether that mirror makes inoperative the vehicle's compliance with the requirements of FMVSS No. 111. However, NHTSA urges vehicle owners not to degrade the safety of any system or device on their vehicles, including the safety of their rearview mirrors. In addition, individual States are responsible for regulating the use of motor vehicles, and a State may have its own requirements with regard to the type of mirrors vehicles must have to be registered in that State.

I hope this information is helpful. For your future reference, I have enclosed an information sheet providing general information about NHTSA's regulations for manufacturers of new motor vehicles and motor vehicle equipment. Please feel free to contact Marvin Shaw of my staff at this address or by telephone at (202) 366-2992 if you have any further questions or need additional information.

ID: nht93-5.22

TYPE: Interpretation-NHTSA

DATE: July 13, 1993

FROM: John Womack -- Acting Chief Counsel, NHTSA; Signature by Stephen P. Wood

TO: Ernest Farmer -- Director, Pupil Transportation, Tennessee State Department of Education, Office of Commissioner

TITLE: None

ATTACHMT: Attached to letter dated 6-25-93 from Ernest Farmer to Chief Counsel, NHTSA (OCC 8815)

TEXT:

We have received your letter of June 25, 1993, with respect to your plan to retrofit three school buses with strobe lights for "the traditional incandescent lights currently used in the eight light overhead warning system on school buses." You ask whether this equipment would "conflict with the provisions of FMVSS 108."

Yes, the substitute system would not conform to S5.1.4 of Standard No. 108 because it is not a school bus signal lamp system meeting the requirements of SAE J887 School Bus Red Signal Lamps, July 1964. Moreover, section 108 (a)(2)(A) of the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1392 (a)(2)(A) ) prohibits a manufacturer, dealer, distributor, or motor vehicle repair business from knowingly rendering inoperative any device or element of design installed in accordance with a Federal motor vehicle safety standard. However, the prohibition does not extend to the vehicle owner. We assume for purposes of this interpretation that the State is the owner of the school buses, and owns the repair facilities where the conversion will occur. Under these circumstances, there is no Federal legal prohibition against the State's conversion to the strobe light system if the work is performed in its own repair shops.

ID: nht93-5.23

TYPE: Interpretation-NHTSA

DATE: July 14, 1993

FROM: John Womack -- Acting Chief Counsel, NHTSA

TO: Charlie McBay -- Chief Engineer, Barrett Trailers, Inc.

TITLE: None

ATTACHMT: Attached to letter dated 6-13-93 from Charlie McBay to NHTSA Office of Chief Counsel (OCC 8816)

TEXT:

We have received your letter of June 13, 1993, asking that this Office review the two drawings you enclosed "for compliance with the upcoming conspicuity requirement", and "ask that our installation have your approval."

Under the National Traffic and Motor Vehicle Safety Act the manufacturer has the responsibility of determining whether its product conforms and then certifies its compliance with all applicable Federal motor vehicle safety standards. The Act does not provide authority for the agency to "approve" or "disapprove" any specific solution to methods of conformance. For this reason, we are unable to advise you in the manner you seek.

However, the agency does provide interpretations when specific questions are asked with respect to the requirements of the standard, and we are pleased to respond accordingly to your inquiries. You have raised four issues for our comment.

1. You have called to our attention that the "outside post" design of the trailers is configured so that the spacing of the posts along the length of the trailers is not the same. The retroreflective material will be evenly spaced in most areas, but breaks between material vary. You have asked whether this will "suffice for evenly distributed."

Under S5.7.1.4.2(a) of Federal Motor Vehicle Safety Standard No. 108, retroreflective sheeting applied to each side of a trailer need not be continuous "as long as not less than half of the length of the trailer is covered and the spaces are distributed as evenly as practicable." As we have advised many times, under Standard No. 108 the determination of practicability is to be made by the manufacturer in fulfillment of its obligation to certify that its product conforms to all applicable Federal motor vehicle safety standards. NHTSA believes that, as a general rule, a manufacturer is in the best position to determine what is practicable for its particular design. However, if that determination appears erroneous on its face, NHTSA will question it. Were you to manufacture trailers with the side conspicuity treatment spacings depicted on your drawings, NHTSA would not question your determination of practicability.

2. You have asked "if an area exists where a minimum 12" strip will not fit, can we install smaller material or must this area stay blank?"

As noted above, under S5.7.1.4.2, a strip of retroreflective material need not be continuous "as long as not less than half of the length of the trailer is covered." Therefore, if exclusion of the area in question would not result in less than half of the length of the trailer being covered, the area may be left

blank.

If additional sheeting is required for a trailer to meet the length requirement, or if a manufacturer simply wishes to add it, it need not be "a minimum 12" strip." S5.7.1.3(d) of Standard No. 108 specifies that each segment of retroreflective sheeting shall have a length of 300 mm (i.e., 12 inches) +/- 150 mm. Therefore, a segment of sheeting as short in length as 150 mm (6 inches) could be applied to the area in question in compliance with the standard. An even shorter segment is permitted if necessary "to clear obstructions" if that should be the reason in your instance where a strip of 300 mm will not fit.

If the length of the area in question is smaller than 150 mm and its coverage is required for the conspicuity treatment on the trailer to meet the length requirement, then any length of material is acceptable.

3. You have asked us to note that the white strips in the upper rear corners do not meet. You have asked "Must white be touching or can there be a gap between the strips?"

Figure 30 "Typical Trailer Conspicuity Treatments" depicts two configurations in which the white strips of retroreflective material intersect at right angles in the upper rear corners. The requirement that Figure 30 illustrates is set forth in S5.7.1.4.1(b), which specifies, in pertinent part, "two pairs of white strips of sheeting, each pair . . . applied horizontally and vertically to the right and left upper contours of the body . . . as close to the top of the trailer and as far apart as practicable." There is no explicit requirement in this paragraph that the horizontal and vertical strips intersect or touch. There is an implicit requirement in the specification that the strips be "as close to the top and as far apart as practicable", but the requirement is subject to the manufacturer's determination of practicability. In other words, if the manufacturer's determination of practicability results in a gap between the strips, NHTSA will not question this determination unless it appears clearly erroneous.

4. You represent that your design makes it impossible "to make a nice continuous square corner", and that "(i)nstallation of the white corners is also closer than 3" from red top rail lights." You ask whether there is "any tolerance on the 3" dimensions?

There is no tolerance on this requirement. S5.7.1.4(b) states that "The edge of white sheeting shall not be located closer than 75 mm to the edge of the luminous lens area of any lamp that is required by this standard." The diagrams you enclose depict the horizontal white strip directly below the clearance lamps, which are required by Standard No. 108, so that each design does not accord with Standard No. 108.

We have some comments on each design. On "Model 80MP6-DD" it appears to us that, under a determination of practicability, the white strips could be lowered until the required minimum spacing between it and the clearance lamp was achieved. There is no prohibition against placing the material on the roll-up door.

The trailer identified as "GNXS-207" raises a more difficult problem because there appears to be no place where the strips could be relocated. Consideration must be given, therefore, to relocation of the clearance lamps. Under Table II of Standard No. 108, clearance lamps are intended to "indicate the overall width of the trailer". Although clearance lamps should be "as near the top . . . as practicable", they need not be "(w)hen the rear identification lamps are mounted at the extreme height of a vehicle" (S5.3.1.4). The rear identification lamps on GNXS-207 are mounted at the extreme height of the vehicle. The clearance lamps could be relocated to the fender where the stop, turn, and taillamps are presently installed. In that location, the clearance lamps would also be better able to fulfill the intent that they indicate the overall width of the trailer, which appears to occur at the fender rather than at the upper part of the body.

We hope that these interpretations are helpful.

ID: nht93-5.24

TYPE: Interpretation-NHTSA

DATE: July 14, 1993

FROM: Zaher A. Obeid -- President & CEO, Petrobeid of Syria

TO: NHTSA

TITLE: Re: Zatalite device for preventing tragical motor vehicle accidents especially on highways

ATTACHMT: Attached to letter dated 7/29/93 (est) from John Womack to Zaher A. Obeid (A41; Std. 108; VSA 108); Also attached to letter dated 8/17/89 from Stephen P. Wood to Alan S. Eldahr (Std. 108)

TEXT:

"Please allow me to submit to you some chosen documents and details of my patented leading invention above, which is intended to be manufactured and distributed in the U.S.A. in the near future.

Prior to such a final step, and as I am quite concerned to make this device as safe and useful as possible, I shall absolutely and always need any serious remark and/or comment, especially from highly experienced adminstrations like yours.

Therefore, please kindly read the attached details carefully, and let me have your esteemed opinion, along with any suggestion that you may find useful.

Your cooperation will be very valuable to me, and shall very much appreciate to hear from you at an early convenience.

Attachment

Zatalite brochure (text and photos omitted).

ID: nht93-5.25

TYPE: Interpretation-NHTSA

DATE: July 15, 1993

FROM: Pat McCue -- Allied Service Systems Manufacturing

TO: Ed Jettner -- Office of the Chief Counsel, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 2/10/94 from John Womack to Pat McCue (A42; Std. 302; Std. 208; Std.. 209; VSA 108(a)(2)(A))

TEXT:

The intent of this letter is to advise your agency of the need for regulation on an occupant restraint system in ambulances. Hopefully, your technical staff can feed back information on how the regulations are put into effect and what criteria you use to test products or components that make up the restraint system.

The NFPA, National Fire Protection Agency, has required an occupant restraint system in ambulances for medics and attendants riding on the bench seat in the back of ambulances. Unlike other occupant restraint systems, the user must have the ability to move about to provide patient care while the vehicle is moving.

A fatal accident in Phoenix, Arizona on June 24, 1992, caused the Phoenix Fire Department to actively pursue a system to protect their personnel riding in the back of ambulances. This incident identified the need for a restraint system.

Allied Service Systems has produced a patented product which will meet the needs of the user. However, I know of no product specifications.

Enclosed are photos of our system, material specifications, and a copy of the NFPA requirement.

Please advise me of any input your agency can provide in terms of how regulations are established and how products are tested to meet standards.

ID: nht93-5.26

TYPE: Interpretation-NHTSA

DATE: July 20, 1993

FROM: Calin Moldovean -- Vehicle Technology Engineer, Automotive & Vehicle Technology Division, TUV America, Inc.; Signature by other (illegible)

TO: John Womack -- Acting Chief, Counselor of the NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 8/18/93 from John Womack to Calin Moldovean (A41; Std. 301; Redbook (2))

TEXT:

I am in need of information on the legal requirements for the introduction, from Europe, of a new "after market" gas cap to the US market and any NHTSA legal and technical requirements in terms of proofs of compliance.

Please send information to the address listed above, to my attention, or reply via Fax.

Your help in this matter is greatly appreciated.

ID: nht93-5.27

TYPE: Interpretation-NHTSA

DATE: July 21, 1993

FROM: John Womack -- Acting Chief Counsel, NHTSA

TO: Lillie Rene Erwin -- 365089, TDC Mt View Unit H-1

TITLE: None

ATTACHMT: Attached to letter dated 5/15/93 from Lillie Rene Erwin to Andrew H. Card Jr. (OCC-8693)

TEXT:

This responds to your May 15, 1993, letter to former Secretary Card. Because your letter concerns motor vehicle safety, it has been referred to the National Highway Traffic Safety Administration (NHTSA) for response. You are concerned with vehicles used by the State of Texas to transport prisoners because these vehicles have metal seats and no occupant restraints for the prisoners and asked who you should contact to voice your complaint.

The National Traffic and Motor Vehicle Safety Act authorizes NHTSA to issue motor vehicle safety standards that apply to the manufacture and sale of new motor vehicles and new items of motor vehicle equipment. NHTSA has exercised this authority to establish a standard which requires seat belts to be installed at all designated seating positions in many, but not all, vehicles. In addition, different belt installation requirements apply depending on the vehicle type, seating position within the vehicle, and the GVWR of the vehicle. Accordingly, I cannot identify the specific belt installation requirements for the vehicle in which you were transported without knowing the date of the vehicle's manufacture, the vehicle's seating capacity, and gross vehicle weight rating (GVWR) of the vehicle. In addition, your concerns about the State of Texas' use of the vehicle are not addressed by Federal law, which addresses only the manufacture and sale of motor vehicles, not their subsequent use.

Because your questions concern the safety of the State of Texas' vehicles used to transport prisoners, you may wish to contact the Governor's Office, the head of the Texas prison system, or your state representative.

I hope you find this information helpful.

ID: nht93-5.28

TYPE: INTERPRETATION-NHTSA

DATE: July 21, 1993

FROM: John Womack -- Acting Chief Counsel, NHTSA

TO: Margaret W. Mouzon -- Mouzon Information Services

TITLE: None

ATTACHMT: Attached to letter dated 6/4/93 from Margaret W. Mouzon to Mary Versailles (OCC-8765), letter dated 3/4/93 from John Womack to Robert A. Ernst, and letter dated 1/19/90 from Stephen P. Wood to Linda L. Conrad (Std. 208)

TEXT:

This responds to your letter of June 4, 1993, requesting information on dealer responsibility for occupant restraint system installation. You asked if a dealer is required to replace a deployed air bag prior to selling a used car. You also asked if the air bag must be operable when a dealer sells a showroom or demonstration model of an "otherwise new" car.

With regard to your first question, I am enclosing two letters that explain legal obligations to replace air bags which have been deployed. The first letter, dated January 19, 1990, is to Ms. Linda L. Conrad. The second letter, dated March 4, 1993, is to Mr. Robert A. Ernst. As explained in those letters, Federal law does not require replacement of a deployed air bag in a used vehicle. In addition, there is no Federal law that prohibits selling a used vehicle with a supplemental restraint that is inoperable because of a previous deployment. However, our agency strongly encourages dealers and repair businesses to replace deployed air bags whenever vehicles are repaired or resold, to ensure that the vehicles will continue to provide maximum crash protection for occupants. Moreover, a dealer or repair business may be required by state law to replace a deployed air bag, or be liable for failure to do so.

With regard to your second question, section 108(a)(1)(A) of the National Traffic and Motor Vehicle Safety Act (the Safety Act; U.S.C. 1397(a)(1)(A)) specifies that, "No person shall manufacture for sale, sell, offer for sale, or introduce or deliver for introduction in interstate commerce, or import into the United States, any motor vehicle or item of motor vehicle equipment manufactured on or after the date any applicable Federal motor vehicle safety standard takes effect under this title unless it is in conformity with such standard ..." (Emphasis added) Section 108(b)(1) of the Safety Act (15 U.S.C. 1397(b)(1)) provides that the prohibitions in section 108(a)(1)(A) "shall not apply to the sale, offer for sale, or the introduction or delivery for introduction in interstate commerce of any motor vehicle after the first purchase of it in good faith for purposes other than resale." Because of these statutory requirements, a dealership cannot legally sell or offer for sale a new car equipped with an air bag installed to meet the requirements of Standard No. 208, Occupant Crash Protection, if the air bag is not functional. A showroom or demonstration model would be considered a new car, as it has never been sold for purposes other than resale.

I am also enclosing a copy of the information sheet referred to in the two letters discussed above. 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.

ID: nht93-5.29

TYPE: Interpretation-NHTSA

DATE: July 21, 1993

FROM: John Womack -- Acting Chief Counsel, NHTSA

TO: K. Aubrey Hottell -- Smith and Robson, Inc

TITLE: None

ATTACHMT: Attached to letter dated 6/7/93 from K. Aubrey Hottell to John Womack (OCC-8760) and letter dated 1/19/90 from Stephen P. Wood to Linda L. Conrad (Std. 208)

TEXT:

This responds to your letter of June 7, 1993, requesting information on "air bag replacement, air bag indicator light functioning, and any requirements or recommendations for indicator lights to be functional upon resale of a vehicle."

With regard to air bag replacement, I am enclosing a letter, dated January 19, 1990, to Ms. Linda L. Conrad. As explained in this letter, Federal law does not require replacement of a deployed air bag in a used vehicle. In addition, there is no Federal law that prohibits selling a used vehicle with a supplemental restraint that is inoperable because of a previous deployment.

With regard to air bag indicator lights, S4.5.2 of Standard No. 208 requires a readiness indicator for an air bag system which is clearly visible from the driver's seating position. After an air bag is deployed, this indicator would show that the air bag system is not operative. Section 108(a)(2)(A) of the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1397(a)(2)(A)) provides that:

No manufacturer, distributor, dealer, or motor vehicle repair business shall knowingly render inoperative, in whole or in part, any device or element of design installed on or in a motor vehicle ... in compliance with an applicable Federal motor vehicle safety standard.

As explained in the Conrad letter enclosed, this provision does not impose an affirmative duty to replace equipment damaged in a crash. Hence, there is no Federal law that prohibits selling a used vehicle with an air bag indicator that is inoperable because of damage in a crash. However, the named commercial entities are prohibited from removing, disabling, or otherwise "rendering inoperative" a functional indicator. Any violations of this "render inoperative" prohibition in the Safety Act would subject the violator to a potential civil penalty of up to $1,000 for each violation.

As noted in the Conrad letter enclosed, our agency strongly encourages dealers and repair businesses to replace deployed air bags whenever vehicles are repaired or resold, to ensure that the vehicles will continue to provide maximum crash protection for occupants. This recommendation would also include repair or replacement of a non-functioning indicator light.

I am also enclosing a copy of the information sheet referred to in the

Conrad letter. 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.