In a previous SAE paper (2001-01-0046), the authors reviewed the National Highway Traffic Safety Administration's (NHTSA) activities in the development of mandatory air bag warnings and analyzed those activities against the framework of the available human factors engineering (HFE) and warning literature. That analysis concluded that in both rulemaking procedures, NHTSA developed labeling requirements that appropriately addressed the respective injury prevention policies and strategies of those respective timeframes. In most regards, the agency properly identified and responded to HFE criteria although some methodological improvement could be obtained.
Since the previous paper, the rulemaking process has continued and there have been significant changes to the mandatory air bag warnings. Some of these changes reflect the improvements in advanced air bag technologies. Other changes reflect an alternate warning scheme to continue to alert consumers to the dangers posed by passenger air bags to children and provide a means of distinguishing vehicles equipped with advanced air bags. The current paper is an extension of the SAE 2001-01-0046 paper and examines the agency's development of the current mandatory air bag warning requirements. 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 although the rulemaking process was somewhat inefficient, spanning over a five year period, NHTSA's analysis of relevant human factors issues appears to have been systematic and complete. The agency did not employ specific testing or formal evaluation as they did in the previous rulemakings, however, the current mandated warnings were subjected to a reasonable HFE analysis and the development process was consistent with the process likely used by most product manufacturers.