Interpretation ID: nht93-1.12

DATE: January 19, 1993

FROM: Steven C. Friedman -- Director of New Product Development, Saddleman, Inc.

TO: Office of the Chief Counsel, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 3-26-93 from John Womack to Steven C. Friedman (A40; Std. 208; VSA 108(a)(2)(A))

TEXT: Our company, Saddleman, Inc., is contemplating the introduction of an aftermarket automotive airbag. The product is manufactured by a Korean company, Line Precision Co., LTD. As you can see in the accompanying brochures, the airbag attaches to the ceiling of the vehicle and discharges downward in between the occupant and the steering wheel or dashboard. The product operates by a mechanical, rather than an electronic, sensor. The response time of the airbag is .05 seconds after sensing frontal impact. This product has been marketed in Korea since early 1992 under the brand name "Challa." Line Precision has applied for T.U.V. approval in Germany, and expects to receive this approval shortly.

Saddleman is based in Logan, Utah, with manufacturing facilities in Utah, Ohio, and S. Carolina. We sell exclusively automotive aftermarket products to such mass merchandisers as Wal-Mart, K-Mart and Sears; and to automotive retailers such as Pep Boys, Trak Auto, and Northern Automotive. We feel that the Challa Airbag, being an attachable, aftermarket product, will fill a market need by providing airbag protection in vehicles where an original equipment airbag is not available.

Saddleman would like to be advised of any federal standards that would apply to this product and of any responsibilities we would have to the NHTSA. We would greatly appreciate a response as soon as possible so that we may address any issues that we have not foreseen.

Attached to brochure (graphics and text omitted)