Mandatory Air Bag Warnings: A Human Factors Analysis of Their Development

The National Highway Traffic Safety Administration (NHTSA) has twice mandated air bag warning labels. This paper reviews and analyzes NHTSA's activities in both the 1993 and 1996 rulemaking procedures against the framework of the available human factors engineering (HFE) and warning literature. It utilizes the full record of the rulemaking process including Federal Register notices and docket submissions to identify the analyses and decisions made by the agency in developing these rules.

This analysis concludes that in both the 1993 and 1996 rulemaking procedures, NHTSA developed labeling requirements that appropriately addressed the respective injury prevention policies and strategies of those timeframes. In most regards, the agency properly identified and responded to HFE criteria although some methodological improvements could be obtained. More significantly, the HFE literature is found to inadequately meet the needs of regulatory agencies or others who would develop precautionary labeling.