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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.

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.