Interpretation ID: 7331
Vice President
USSC Group, Inc.
20 Union Hill Road
West Conshohocken, PA 19428
Dear Mr. Hammarskjold:
This responds to your letters of May 28, 1992 concerning suspension seats. Your first letter states that you have been asked by SCRTD in Los Angeles to develop a system that will allow your suspension seats for the driver's seating position in transit buses to tilt from side-to-side. Your letter states:
In addition, USSC is concerned that there are not applicable FMVSS requirements that address a side-to- side strength requirements. 207/210 requires a pull from the front of the seat. What happens if there is a side impact on a suspension seat that has a ball and socket joint. Are there any applicable performance requirements that may apply to such a system.
With respect to seats which tilt side-to-side, you are correct that Federal Motor Vehicle Safety Standard No. 207, Seating Systems, does not include a performance requirement addressing side-to-side strength. Standard No. 207 requires certain specified forces to be applied only in a forward direction and in a rearward direction. All seats, in all vehicles, except for side-facing seats or passenger seats in buses, must be capable of withstanding these forces when tested in accordance with the S5 of Standard No. 207.
However, you should be aware that manufacturers are subject to the requirements in 151-159 of the Safety Act concerning the recall and remedy of products with safety defects. The defect responsibility is a broad one and would include the side-to-side performance of your seat. In the event that NHTSA or a manufacturer determines that a vehicle containing your seat has a safety-related defect, the manufacturer would be responsible for notifying purchasers of the defective equipment and remedying the problem free of charge. You may be interested in a current proposal to amend Standard No. 207 to establish revised test procedures for pedestal seats. I have enclosed a copy of the notice for your information.
Your second letter asks when shoulder belts will be required on suspension seats. The safety belt installation requirements are set forth in Standard No. 208, Occupant Crash Protection. This standard specifies requirements based on vehicle type and seating position within the vehicle, not based on seat design. I have limited the following discussion of safety belt requirements to trucks and buses, as I am unaware of any passenger cars or multipurpose passenger vehicles which contain suspension seats. As explained below, shoulder belts are required at every forward-facing outboard seating position in trucks with a GVWR of 10,000 pounds or less; at the driver's seating position and at every forward-facing outboard seating position in buses, other than school buses, with a GVWR of 10,000 pounds or less; and at the driver's and right front passenger's seating positions in school buses with a GVWR of 10,000 pounds or less. Shoulder belts are not required at any other seating positions in these vehicles or in trucks or buses with a GVWR of more than 10,000 pounds.
The requirements for trucks are contained in sections S4.2 and S4.3 of Standard No. 208. Sections S4.2.2 and S4.2.3 of Standard No. 208 give vehicle manufacturers a choice of three options for providing occupant crash protection in trucks with a GVWR of 10,000 pounds or less, manufactured on or after September 1, 1991 and before September 1, 1997. Option 1, set forth in S4.1.2.1, requires vehicle manufacturers to provide automatic protection at the front outboard seating positions, lap or lap/shoulder belts at all other seating positions, and either meet the lateral crash protection and rollover requirements by means of automatic protection systems or have manual safety belts at the front outboard seating positions such that those positions comply with the occupant protection requirements when occupants are protected by both the safety belts and the automatic protection. Option 2, set forth in S4.1.2.2, requires vehicle manufacturers to provide a lap or a lap/shoulder safety belt at every seating position, have automatic protection for the front outboard seats, and have a warning system for the safety belts provided. Option 3, set forth in S4.1.2.3 requires the manufacturer to install lap or lap/shoulder safety belts at every seating position and to have a warning system for those belts. In addition, each Type 2 seat belt assembly (i.e., lap/shoulder safety belts) installed at a front outboard seating position in trucks with a GVWR of 8,500 pounds or less must satisfy the dynamic testing requirements in S4.6.
S4.2.4 of Standard No. 208 specifies that a Type 2 seat belt assembly must be installed at each forward-facing rear outboard seating position in trucks with a GVWR of 10,000 pounds or less, manufactured on or after September 1, 1991.
Section S4.2.5 of Standard No. 208 specifies a phase-in of trucks and buses with a GVWR of 8,500 pounds or less that must satisfy the requirements of S4.1.2.1 (Option 1 above). Twenty percent of trucks and buses manufactured on or after September 1, 1994 and before September 1, 1995 must meet this requirement; 50 percent of trucks and buses manufactured on or after September 1, 1995 and before September 1, 1996; 90 percent of trucks and buses manufactured on or after September 1, 1996 and before September 1, 1997. All trucks and buses with a GVWR of 8,500 pounds or less manufactured on or after September 1, 1997 must comply with the requirements of S4.1.2.1.
Section 4.3.1 gives vehicle manufacturers a choice of two options for providing occupant crash protection in trucks with a GVWR of more than 10,000 pounds manufactured on or after September 1, 1990. Option 1, set forth in S4.3.1.1, requires vehicle manufacturers to provide an automatic protection system at all seating positions that meets the frontal and lateral crash protection and rollover requirements. Option 2, set forth in S4.3.1.2 requires vehicle manufacturers to install lap or lap/shoulder belts at every seating position. In addition, S4.3.2 specifies that, if a manufacturer chooses to comply with Option 2, the lap belt or pelvic portion of a lap/shoulder belt must have either an emergency locking retractor (ELR) or an automatic locking retractor (ALR).
The requirements for buses are contained in S4.4 of Standard No. 208. Section 4.4.1 gives vehicle manufacturers a choice of two options for providing occupant crash protection in buses manufactured on or after September 1, 1990. Option 1, set forth in S4.4.1.1, requires vehicle manufacturers to provide an automatic protection system at the driver's seating position that meets the frontal and lateral crash protection and rollover requirements. Option 2, set forth in S4.4.1.2 requires vehicle manufacturers to install a lap or lap/shoulder belt at the driver's seating position. In addition, S4.4.2.2 specifies that, if a manufacturer chooses to comply with Option 2, the lap belt or pelvic portion of the lap/shoulder belt must have either an ELR or an ALR.
Section S4.4.3 requires buses, other than school buses, with a GVWR of 10,000 pounds or less, manufactured on or after September 1, 1991, to have a lap/shoulder belt at the driver's seating position and at every front and rear forward-facing seating position, and either a lap belt or a lap/shoulder belt at every other seating position. School buses with a GVWR of 10,000 pounds or less, manufactured on or after September 1, 1991, are required to have a lap/shoulder belt at the driver's and right front passenger's seating positions, and either a lap belt or lap/shoulder belt at every other seating position. As mentioned previously, buses with a GVWR of 8,500 pounds or less manufactured on or after September 1, 1994 are subject to the phase-in requirement for automatic occupant protection.
I hope you find this information helpful. If you have any other questions, please contact Mary Versailles of my staff at this address or by phone at (202) 366-2992.
Sincerely,
Paul Jackson Rice Chief Counsel
Attachment
ref:207#208 d:8/10/92