Examples of Issues

Since Retiring from NHTSA, Allan Kam has Consulted with Industry and Litigants on Numerous Issues Relating to NHTSA

Issues 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
  • Inadequacy of certain FMVSSs
  • How a product can comply with a FMVSS and still be defective
  • FMVSSs 205 (glazing); 206 (door locks); 207 (seating); 216 (rollovers and roof crush); 218 (motorcycle helmets)
  • Investigation of tire defects; tire safety standards
  • Truck underride
  • Preemption or lack thereof
  • 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
  • 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)

Allan J. Kam

Allan was the Senior enforcement attorney for the National Highway Traffic Safety Administration (NHTSA), U.S. Department of Transportation. He was the first NHTSA attorney to receive the agency’s Distinguished Career Service Award.
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Allan J. Kam