Interpretation ID: nht95-1.70

TYPE: INTERPRETATION-NHTSA

DATE: February 15, 1995

FROM: Lee Rabie -- President, Enerco, Inc.

TO: Office of the Chief Counsel, NHTSA

TITLE: Re: Vehicle Air Bag Restraint Systems

ATTACHMT: ATTACHED TO 4/8/95 LETTER FROM PHILIP R. RECHT TO LEE RABIE (A43; STD. 208); ALSO ATTACHED TO 1/19/90 LETTER FROM STEPHEN P. WOOD TO LINDA L. CONRAD (STD. 208); ALSO ATTACHED TO 3/4/93 LETTER FROM JOHN WOMACK TO ROBERT A. ERNST

TEXT: Dear Sirs

The purpose of this letter is to obtain information from you and your Agency regarding any legal requirements or regulations of the Federal government for recycling/remanufacturing of vehicle Air Bags.

First, let us introduce ourselves. Enerco, Inc. is an industrial electronics firm that manufactures a line of industrial electronic products. Enerco has been in the electronic design and manufacturing business for over twenty years. Please find enclose d some of our data sheets that show a few of the products we manufacture which are used by local, state and federal governments for traffic control.

For some time we have been interested in vehicle Air Bags and the possibility of recycling Air Bags. We are aware of the performance requirements for active and passive restraint systems for the protection of vehicle occupants in crashes as promulgated by the National Highway Traffic Safety Administration, Department of Transportation, in 49 CFR Ch. V, Section 571.208; Standard No. 208; Occupant Crash Protection). We know that recycling of the Bags is physically possible because we have developed a me thodology for doing so. However, we are concerned about any requirements of the laws and regulations which your Agency has oversight responsibility as they relate to the acceptance and performance of recycled Air Bags.

Air Bag systems are being required be installed in all cars sold in the United States. An Air Bag Restraint System is extensive and is comprised of the Air Bag and it's associated controls, sensors, computers, cables and indicators. The cost of the Bags themselves (2 Bags will be required for all cars) as purchased new from each manufacturer is very high. As the time period in which these systems have been required increases, and as the number of newer vehicles on the road increases, the number of Bag s which have actually been deployed in crashes is dramatically increasing.

As it stands now, after a vehicle crashes with deployment of an Air Bag, the Bag is removed form the vehicle and is replaced with a new Bag supplied by the manufacturers. The original Bag goes to waste. Additionally, disposing of the blown Air Bag is a lso a problem due to fact that other environmental health regulations prohibit (actual label on the side of the Bags) the placement of Bags in landfills. Therefore wrecking yards and repair shops have a problem of disposing the Bags.

In addition to the waste of reusable equipment and disposal problems there is another large expense problem. As indicated above the cost of a new Bag is very high. This is because the Bag is not recycled and usually the original manufacturers are the o nly source for the replacement Bags. The high replacement cost must be paid by the vehicle owner or his insurance company, even if the vehicle in which it deployed did not sustain major damage. All this points to the fact that there is a dramatic need in our society to have the choice of purchasing from a secondary source quality recycled Air Bags.

Our proposed recycling program would take the original blown Bags which were made and supplied by the original manufacture of the vehicle, and remanufacture them to the original standards. Blown Air Bags and the vehicles in which they have been blown ha ve been examined by us. The vehicles metal structure and steering wheel are designed to withstand the Air Bag deployment. The Bag has a valve to allow deflation without damaging of the Bag. This means that washing, cleaning, refolding, supplying of a new squib and new chemical charge and resealing of the flap that is made to open to allow Bag deployment, would be the focus of the recycling/remanufacturing process.

Enerco would appreciate any facts, information, discourse, thoughts or opinions from your department regarding our proposal to recycle/remanufacture Air Bags. This would include your opinion on whether the present law and regulations would allow recyclin g/remanufacture of the Air Bags (Bags only, not the sensors or computers) to the same MTBF standards using existing, proven technology.

Thank you for your consideration of this request. Your timely reply will be very much appreciated.

Brochures omitted.