Interpretation ID: nht95-1.81

TYPE: INTERPRETATION-NHTSA

DATE: February 28, 1995

FROM: Chong D. Lee -- President, TMR International, Inc.

TO: Mr. Philip Recht -- Office of the Chief Counsel, NHTSA

TITLE: NONE

ATTACHMT: ATTACHED TO 4/10/95 LETTER FROM PHILIP RECHT TO CHONG D. LEE (A43; STD. 208)

TEXT: Dear Mr. Recht:

The purpose of this letter is to request the opinion and advice of the National Highway Traffic Safety Administration on the legality and potential legal risks of an automotive product intended to increase occupant safety.

Our company, TMR International, Inc., plans to import, for North American sale, an aftermarket driver's side airbag. The intent is to offer this product as a safety improvement for customers whose cars and trucks were manufactured without an airbag as o riginal equipment. The airbag comes in assembly with a steering wheel and is intended for installation as a unit in replacement of the vehicle's OEM steering wheel.

We are requesting the opinion of NHTSA as to; a) Whether such a product as described is legal for U.S. sale; b) Legal procedures, testing or submissions required to certify the product for U.S. sale; c) Applicable Federal law (e.g., FMVSS 208) d) Actions or registrations required to reduce legal risks; e) Any other information of which we should be aware.

Thank you for prompt attention. We look forward to bringing to market, as soon as possible, this important safety improvement product.