Mr. Rolf Bergmann
Volkswagen of America, Inc.
3800 Hamlin Road
Auburn Hills, MI 48326
Dear Mr. Bergmann:
This is in response to your letter, in which you requested an interpretation of the passenger air bag off telltale requirement of Federal Motor Vehicle Safety Standard (FMVSS) No. 208, Occupant Crash Protection (S19.2.2). Specifically, you seek confirmation of your interpretation that FMVSS No. 208 does not prohibit the addition of a supplementary telltale image adjacent to the automatic suppression system status telltale. As discussed below, we agree with your interpretation that FMVSS No. 208 does not prohibit the symbol #K.05 for passenger air bag off or not available in the International Standard, ISO 2575, Road Vehicles Symbols for Controls, Indicators and Telltales, from being placed adjacent to the textual automatic suppression system telltale required by FMVSS No. 208, S19.2.2.
By way of background, on May 12, 2000, the National Highway Traffic Safety Administration (NHTSA) published a final rule requiring all light passenger vehicles to be equipped with advanced air bag systems. 65 FR 30680. These requirements are codified in FMVSS No. 208. One of the advanced systems contemplated by the passenger side air bag is an automatic suppression system, whereby the air bag is turned off when a small child is present in the front passenger seat. One of the required elements of such a system is a telltale that informs the vehicle occupants that the air bag has been suppressed when the passenger seat is occupied by a person that the suppression system identifies as a child. The requirements for the telltale are specified in paragraph S19.2.2 of FMVSS No. 208. The agencys December 18, 2001 response to various petitions for reconsideration of the final rule made some minor changes to S19.2.2. 66 FR 65376 (Dec. 18, 2001).
S19.2.2 requires that each vehicle equipped with an automatic suppression system have at least one telltale that emits a light when the air bag is deactivated and does not emit light when the air bag is activated, except when the passenger seat is not occupied. The
telltale must meet requirements further detailed in paragraph S19.2.2. Specifically, S19.2.2(b) requires the specific identifying words PASSENGER AIR BAG OFF or PASS AIR BAG OFF on the telltale or within 25 mm (1.0 in) of the telltale. However, nothing in FMVSS No. 208 prohibits the use of supplemental identifying symbols. Accordingly, NHTSA takes the position that the automatic suppression system telltale requirements of FMVSS No. 208 S19.2.2 do not prohibit the additional identification by the symbol specified by the ISO standard.
We observe that while the agency rejected DaimlerChryslers 2000 request in its petition for reconsideration of the May 2000 advanced air bag final rule, that manufacturers be allowed to use a universal symbol representing the status of the air bag rather than specified words, this was because the agency believed it was premature to allow a universal symbol in lieu of the written warning. The agency did not state its position on the use of a universal symbol indicating that the passenger air bag is off in addition to the written warning required by FMVSS No. 208 S19.2.2. See 66 FR 65376, 65400.
If you have any further questions, please do not hesitate to contact Sarah Alves of my staff at (202) 366-2992.
Anthony M. Cooke