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Examples of Issues
Since retiring from NHTSA, Allan Kam has consulted with industry and litigants on numerous issues relating to NHTSA, including:
- Responding to NHTSA inquiries
- Whether a product should be (or should have been) recalled due to a safety-related
defect
- Whether information was improperly withheld from NHTSA
- NHTSA’s limited resources to investigate defects and FMVSS noncompliances
- Applicability and minimal nature of FMVSSs
- Rollovers and roof crush (FMVSS 216)
- Investigation of tire defects; tire safety standards
- Truck underride
- Preemption or lack thereof
- Inadequacy of certain FMVSSs
- History of Standard 208, airbag warning labels, and related preemption issues
- Crashworthiness investigations and occupant crash protection requirements
- Standard 213 (child seats) requirements
- NHTSA child seat defect investigations
- Seat belts and seat belt buckles; rear seat lap and shoulder belts
- How a product can comply with a FMVSS and still be defective
- Rulemaking on electrical system integrity
- Rulemaking on fuel system integrity (FMVSS 301)
- Refuting canards about NHTSA, e.g., that NHTSA found “no defect”
or gave the product a “clean bill of health”
- Explaining agency actions (e.g. political influences)
- FMVSSs 205 (glazing); 206 (door locks); 207 (seating); 218 (motorcycle helmets)
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