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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)