Interpretation ID: 9190
Director and General Manager
Nissan Research and Development, Inc.
750 17th Street, N.W.
Suite 902
Washington, DC 20006
Dear Mr. Hachiya:
This responds to your letter of October 12, 1993, asking several questions concerning the labeling requirements of the recent final rule mandating the installation of air bags in passenger cars and light trucks (58 FR 46551, September 2, 1993). Your questions concern the labeling requirements in this final rule.
As you may know, NHTSA has received two petitions for reconsideration of the September 2 final rule. The petitions raise issues concerning the labeling requirements. We will address your first, second, and fourth questions in the notice responding to the petitions for reconsideration.
Your other questions and the response to each follow.
The mandatory air bag rule establishes type size and format requirements for the air bag maintenance label (section 4.5.1(a)), but no similar requirements for the air bag warning label in section 4.5.1(b). Are we correct in understanding that the lettering of the warning label may be of any size or format, so long as the letters are legible? May different type size and formats be used if the two labels are combined?
You are correct that there are not any size requirements for the air bag warning label. Therefore, so long as the information on the label is legible, the lettering may be of any size. It is unclear what you mean by format, but the warning label must contain the exact words, in the exact order, as specified in section 4.5.1(b). The issue of combining warning and maintenance labels will be addressed in the notice responding to the petitions for reconsideration.
It is our understanding that warning labels that do not refer to air bags or seat belts may continue to be placed on the side of the sun visor opposite from the air bag warning label. Nissan currently places a label on the sun visor of a convertible model which provides instructions regarding the use of the convertible top. May this type of label continue to be placed on the sun visor, so long as it is on the side of the visor opposite from the air bag warning label?
Section S4.5.1(b)(2) specifies (1) that no other information shall be on the same side of the sun visor as the air bag warning label, and (2) that no other information concerning air bags or seat belts shall appear anywhere on the sun visor. Therefore, you are correct that information concerning the operation of a convertible top could be placed on the side of the sun visor opposite the side with the air bag warning label.
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.
Sincerely,
John Womack Acting Chief Counsel
ref:208 d:11/18/93