Auto Recyclers Respond to NHTSA Concerns Over Recycled Air Bags

          Recycled Air Bags Remain a Safe Alternative for Consumers

    FAIRFAX, Va., Feb. 8 The Automotive Recyclers Association
(ARA) is concerned by recent misleading statements that appear in a letter
released by the U.S. Federal National Highway Traffic Safety Administration
(NHTSA).  This letter, addressing the use of recycled airbags, was written by
Frank Seales, Jr., Esq., Chief Counsel of NHTSA, in response to an inquiry
from Ms. Melba J. Collins of Little Rock, AR.

    ARA's concerns were raised due to the fact that Mr. Seales's letter fails
to cite any type of source to support its position.  Mr. Seales states "an air
bag may be rendered inoperable by damage in a low-speed crash, even if it has
not deployed."  However, airbags are designed to withstand varying conditions
-- some extreme -- and still deploy in a collision as they were designed to
when new.  If an airbag did not deploy, it means that the conditions did not
warrant its deployment and it can remain intact for use at a later date, in
the original vehicle or as a viable option in another vehicle.  Either way,
testing has shown that the airbag will perform to meet safety standards.

    Mr. Seales's unsupported statement has enormous implications for
carmakers, insurers and consumers alike.  If his contentions were true, then
all air bags would have to be replaced after every "crash."  Air bags are
designed to withstand shocks, including shocks delivered by low speed crashes
that do not warrant deployment.  Thus, car manufacturers neither require nor
recommend, as far as we are aware, that air bags be changed after low speed
incidents.  Furthermore, the cost implications of this statement by Mr.
Seales, for automobile insurers and therefore consumers, would be
astronomical.

    The Automotive Recyclers Association (ARA) stands by the use of
undeployed, recycled Original Equipment Manufacturer (OEM) air bags as viable,
economical and safe alternatives to the use of new, costly OEM air bags when
properly, professionally evaluated, handled, shipped and installed.  "We
believe this is a cost effective option for a consumer," said Bill
Steinkuller, Executive Vice President of ARA, "but, more importantly, we also
believe that based on research, this is a safe alternative as well."

    Mr. Seales's letter also states that "the use of a salvaged air bag raises
additional safety issues."  In fact, we are unaware of any factual data that
exists to support this argument, and we believe there is none.  To the
contrary, studies by ARA, Insurance Corporation of British Columbia (ICBC) and
Airbag Testing Technology (ATT) have consistently shown that the performance
of undeployed, recycled OEM air bags is the same as new OEM supplied airbag
modules for repair.  ATT showed, based on studying forces and energy related
to air bag deployment and occupant performance, new OEM parts and recycled air
bags are statistically indistinguishable.  Long-term experiences in the field,
specifically units in use in Canada for close to a decade without a negative
incident, have also shown that undeployed, recycled OEM airbag units are a
wholly safe alternative to new OEM replacement parts.

    "These tests reinforced our conclusion that undeployed, recycled OEM
airbags are safe and reliable for use, and we hope consumers are not misled by
what we believe to be unfounded statements in Mr. Seales letter," Steinkuller
said.

    NHTSA would do well to focus its efforts on the real and serious problem
-- installation of "dummy" airbag covers, which in fact portend deadly risks
to consumers.  ARA believes the availability of lower-cost undeployed,
recycled OEM airbags as replacement parts greatly reduces the principal or
perhaps only incentive for consumers to use dummy covers, namely the cost of
new OEM replacement air bags.