Can a modifier use the exemption for FMVSS 208 to disconnect air bags or install air bag on/off switches?
Yes, unless it is the only modification being made that would take the vehicle out of compliance; 49 CFR Part 595 Subpart B covers this situation. The new exemption to FMVSS 208 applies only where a retrofit air bag on-off switch cannot accommodate the individual’s disability and the air bag system is affected in the course of a necessary modification. An example is deleting the air bag because a client needs a reduced-diameter steering wheel. The seating position must be supplied with a lap and shoulder safety belt meeting the requirements of FMVSS Nos. 209 and 210. If the only thing you need to do to accommodate the vehicle user is to install an air bag on/off switch, follow 49 CFR Part 595 Subpart B. Use the make inoperative exemption for FMVSS 208 at 49 CFR 595.7(c)(14), if the client needs a switch or air bag deactivation in conjunction with other modifications for which you will be using exemptions under 49 CFR Part 595 Subpart C. If the only thing you plan to do that will take t