Safety Affairs and Vehicle Testing
Mail Code 4F02
3800 Hamlin Road
Auburn Hills, MI 48326
Dear Mr. Haenchen:
This responds to your letter requesting an interpretation of Standard No. 208's sun visor labeling requirements. As noted by your letter, S4.5.1(b) requires a sun visor label with specific wording regarding certain cautions to avoid serious injury from possible air bag interactions with front seat vehicle occupants. You asked whether it is permissible to add to the sun visor label statements or references concerning side impact air bags for vehicles equipped with these devices. As discussed below, the answer is no.
You state in your letter that, in the interest of safety, Volkswagen believes it would be appropriate and desirable to add reference to side air bags to the sun visor label of vehicles equipped with these devices. You suggest adding a statement in the form of a heading, either above or below the phrase "Caution to Avoid Serious Injury," such as "This vehicle is equipped with front and side impact air bags." You also suggest adding the phrase "Front and Side Impact Air Bags" to the side of the sun visor with the air bag alert label.
Standard No. 208 specifically addresses the question of whether information in addition to the required cautions may be provided on the sun visor. S4.5.1(b)(2) provides that "(e)xcept for the information on an air bag maintenance label placed on the visor pursuant to S4.5.1(a) of this standard, no other information shall appear on the same side of the sun
visor to which the label is affixed." (Emphasis added.) That section also provides that "(e)xcept for the information in an air bag alert label placed on the visor pursuant to S4.5.1(c) of this standard, or in a utility vehicle label that contains the language required by 49 CFR 575.105(c)(1), no other information about air bags or the need to wear seat belts shall appear anywhere on the sun visor." (Emphasis added.)
You suggest in your letter that identifying phrases about side impact air bags are not really "other information" in general or "other information about air bags." However, the regulation's terms are sufficiently broad to include any references or statements about side impact air bags. I can only conclude that the highlighted language above prohibits adding to the sun visor label any references or statements about side impact air bags. I note that you can, of course, include such references or statements in locations other than the sun visor.
We believe it is appropriate, however, to consider whether particular statements on the sun visor should be permitted or required for vehicles with new kinds of air bags, such as air bags for side impact protection. In our newly issued notice of proposed rulemaking to reduce the adverse effects of air bags to children, we have specifically requested comments on that question. We would encourage you to address this issue in your comments.
If you have any further questions, please feel free to call Edward Glancy of my staff at (202) 366-2992.
Samuel J. Dubbin