Interpretation ID: aiam4369
Vice President
Product Compliance and Service
Mercedes-Benz of North America
Inc.
P.O. Box 350
Montvale
NJ 07645;
Dear Mr. Faber: Thank you for your letter of April 16, 1987, concerning th requirements of Standard No. 208, *Occupant Crash Protection*. In particular, you asked for an interpretation of the requirements of S4.5.1 of the standard. I hope that the following discussion answers your question.; S4.5.1 of Standard No. 208 provides that each vehicle with a cras deployed occupant protection system must have a label setting out a manufacturer's recommended schedule for the maintenance or replacement needed to keep the performance of the occupant protection system at the level required by the standard. S4.5.1 further provides that 'the label shall be permanently affixed to the vehicle within the passenger compartment.' You explained that at the present time, you place the label for your air bag system on the glove box door. You further explained that you place all other important safety-related information, such as the certification label and tire information placard, on the latch post for the driver's door.; You stated that you want to relocate the air bag label from the glov box door to the latch post on the driver's side. You explained that one of the benefits of the new location is that it will establish a common location for the operator to quickly find important information. You said that the new location should remind vehicle operators of the replacement schedule since the tire pressure placard, which is routinely reviewed by the vehicle operator, is in the same location. Finally, you noted that dealership service personnel will be alerted to the replacement schedule since 'it is common practice for Service Writers to copy down the VIN from the certification label on the driver door latch post.'; NHTSA agrees that a label placed on the driver's latch post would mee the requirements of S4.5.1. The purpose of the location requirement is to place the replacement and maintenance schedule in a location that can be easily observed by the vehicle owner. Thus, the standard requires the label to be within the occupant compartment of the vehicle. The agency considers a label placed on the latch post, which is inside the exterior surface of the vehicle and is a part of the physical structure that constitutes occupant compartment, as meeting the location requirement. As you pointed out in your letter, the latch post is already used as a location for other important safety-related information about the vehicle.; If you have any further questions on this standard or need additiona information, please let me know.; Sincerely, Erika Z. Jones, Chief Counsel