Mr. Shintaro Nakatsuka
Vice President and General Manager
Mazda (North America), Inc.
1025 Connecticut Avenue, NW
Washington, DC 20036
Dear Mr. Nakatsuka:
This responds to your request for an interpretation of Standard No. 208's requirements for passenger air bag manual cut-off devices. You note in your letter that S184.108.40.206 of the standard requires a telltale on the instrument panel to notify vehicle occupants when the passenger air bag has been deactivated by use of the manual cutoff device that is permitted in certain vehicles under the provisions of S4.5.4. You also note that S220.127.116.11(d) specifies that the telltale "shall not be illuminated at any time when the passenger air bag is not deactivated." You state that it is your belief that this specific prohibition would not apply to the illumination of the telltale for a brief period during a bulb check when the vehicle is started, and ask us to advise whether this is correct. As discussed below, your understanding is correct.
While Standard No. 208 does not address the subject of bulb checks for cut-off device telltales, the general subject of bulb checks for telltales is addressed in other safety standards. S5.3.1 of Standard No. 101 specifies for most telltales that "(a) telltale shall not emit light except when identifying the malfunction or vehicle condition for whose indication it is designed or during a bulb check upon vehicle starting." Moreover S5.3.2 of Standard No. 105 requires a bulb check function for brake indicator lamps.
We agree with your view that the concept of a bulb check is well understood by vehicle owners and operators and therefore, if a bulb check function was to be incorporated in the telltale required by S18.104.22.168, there would be no danger of confusion and it could possibly enhance the reliability of the manual cut-off switch device permitted by S4.5.4. Given general industry practice in this area and the treatment in other Federal motor vehicle safety standards of bulb checks for telltales, we agree that the prohibition in S22.214.171.124(d) of Standard No. 208 should be interpreted as not applying to the illumination of the cut-off device telltale for a brief period during a bulb check when the vehicle is started.
I hope this information is helpful. If you have any further questions, please feel free to call Edward Glancy of my staff at (202) 366-2992.
Acting Chief Counsel