Interpretation ID: 13171.jeg

Mr. Dietmar K. Haenchen
Process Leader
Safety Affairs and Vehicle Testing
Volkswagen
Mail Code 4F02
3800 Hamlin Road
Auburn Hills, MI 48326

Dear Mr. Haenchen:

This responds to your letter concerning the recent air bag warning label rule (Docket 74-14; Notice 103). You asked whether it is permissible to place a reference to the owner's manual, such as "See owner's manual for further important safety information," on the side of the sun visor bearing the air bag alert label. As discussed below, the answer is no.

Section S4.5.1(b)(3) of Standard No. 208 sets forth the following limitation on providing additional information, beyond what is required by the standard, on the sun visor:

Except 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 sun visor warning label is affixed. Except 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.

Thus, on the warning label side of the visor, the only information, of any sort, that may appear is that specified for the warning label and for the air bag maintenance label. On the alert label side, the only information about air bags or the need to wear seat belts that may appear is that specified for the alert label.

We interpret the term "information" broadly and consider a reference statement such as "See owner's manual for further important safety information" or similar language, added to the alert label side of the visor, to be information about air bags or the need to wear seat belts and therefore precluded by section S4.5.1(b)(3). This conclusion follows from both the context in which this statement would be provided, and the purposes for providing the statement. We also note that the statement is essentially taken from the previous air bag warning label specified by Standard No. 208, which the agency expressly decided to eliminate.

I hope this information is helpful. If you have further questions, please feel free to call Edward Glancy of my staff at (202) 366-2992.

Sincerely,

John Womack
Acting Chief Counsel

ref:
1/31/97