prove impractical due to the number of possible combinations of these elements.” Ferrari also
opposed the proposed language change citing the same argument as that offered by AIAM.
Advocates supported both the proposed language change and extending the information
requirement beyond passenger cars to include “all passenger and non-passenger light vehicles
with a gross vehicle weight rating (GVWR) of 4,536 kilograms (10,000 pounds) or less,” on the
basis that this information would be valuable for safety research and data analysis.
Agency Analysis and Response:
The current language in Part 565 was sufficient when the range of restraint equipment
that was either required or was available in the marketplace consisted primarily of seat belts and
front seat airbags. Today, in addition to seat belts, front seat air bags are mandatory and restraint
equipment technology has advanced to the point where there are many variations both in
required equipment and in equipment, such as side air bags, that is offered in the marketplace.
The new language is intended to capture and make available, through a vehicle’s VIN, more
complete and accurate information regarding occupant restraint in each vehicle manufactured for
sale in the U.S.
The agency does not agree with the Alliance and the AIAM that this change is overly
burdensome. The agency is aware that some major manufacturers represented by these two
organizations are already submitting comprehensive restraint related VIN deciphering
information to NHTSA under 49 Part 565.7(c) that would comply with the amended
requirements. This suggests to the agency that if a manufacturer knows well in advance of
restraint system changes that will occur during a vehicle’s production run, creating a VIN to
account for those changes would be no more difficult than accounting for the different engines
that can be installed in a particular vehicle model. In those cases where an unanticipated running