Citizen.Org

COMMENTS ON AUTO MANUFACTURER POSITIONS

Allows mass production of generic air bags that are simpler to produce (not tested by model);

Manufacturers won t have to produce more expensive air bags, making production costs cheaper;

There is less likelihood of recalls for defective air bags;

It is very difficult to affirmatively prove that someone was harmed in a high-speed crash due to inadequate air bag protection (faulty design is harder to pinpoint).

The Auto Industry Frequently Shifts Its Ground On Air Bag Issues:

In the late 1960s to early 1970s, some manufacturers claimed that air bags were not viable safety devices, but GM produced 10,000 vehicles in 1974-76 with dual air bags that worked exceptionally well;

Before NHTSA in 1997 permitted the generic sled test under which the manufacturers "depowered" their air bags, manufacturers claimed it was only necessary as an interim measure; once the sled test was adopted as an alternative to the 30 mph crash test, manufacturers insisted it be made permanent;

In September 1999, despite arguing that they could not meet any test more stringent than the generic sled test, manufacturers endorsed a slightly more stringent 25 mph crash test;

Auto companies now say that they can meet the requirements for the 50th male with "depowered" air bags, even though the manufacturers alleged since 1996 they could not.

Auto Manufacturers Push For Lowest Common Denominator Regulation:

Manufacturer trade associations support only the lowest common denominator position among the member companies;

Manufacturers have pressured their suppliers to support the manufacturer program -- suppliers were outspoken about technological advances for air bags prior to this rulemaking, but now support the manufacturer party line;

Manufacturers often assert that a particular safety improvement is impracticable and cannot be done. Yet, once required, the manufacturers comply and then advertise to consumers that the feature exceeds federal safety standards (e.g., air bags, improved side impact, upper interior head impact protection).

Manufacturers adhere to the bare minimum standards. Unless they are prodded by regulations requiring better performance, they will not do so, as evidenced by the industry s failure to introduce advanced air bags in response to the 1991 ISTEA air bag mandate.

Manufacturers Claim They Must Exceed Requirements By A 20% Margin:

Manufacturers may design to exceed a standard by a 20% margin, but because of "prototype to production slippage," that is not equivalent to a 20% production margin;

NHTSA stated in the SNPRM that testing proves that neither pre-1998 model year air bags nor "depowered" air bags were produced to 20% production margins; i.e., the air bags did not exceed injury criteria by 20% margins.

Manufacturers raised this issue when their "depowered" production vehicles passed NHTSA s 30 mph crash tests, but some passed by less than a 20% margin.

Bias Toward Unbelted Occupants:

Some argue that the 30 mph unbelted crash test is biased toward unbelted occupants and that it undermines efforts to increase belt use, but the opposite is true;

Manufacturers agree that belted occupants are well protected in 30 mph crash tests.

In deadly 30-plus mph crashes, unbelted occupants (such as teenagers) have no other viable protection except air bags;

Unbelted occupants are killed in disproportionate numbers in fatal frontal crashes (the unbelted are over represented in the fatality statistics);

Belt use is critical and strongly supported by consumers and manufacturers, which is why it has increased and why research is being conducted and expenditures are made on developing belt technologies (such as load limiters and pre-tensioners), on enacting primary enforcement laws, and on behavioral efforts to increase belt use rates.

Auto companies lobbied for a statutory provision giving a design priority to belted occupants, but it was rejected by Congress as morally repugnant.

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