Interpretation ID: 86-6.2

TYPE: INTERPRETATION-NHTSA

DATE: 12/01/86

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Mr. Alvin A. Leach

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. Alvin A. Leach Manager Corporate Transportation Services Carolina Power & Light Co. PO BOX 1551 Raleigh, NC 27602

Dear Mr. Leach:

Thank you for your letter of September 5, 1986, to Administrator Steed concerning the safety belt installation requirements for heavy trucks. The Administrator has asked my office to respond since you asked for an interpretation of the requirements of Standard No. 208, Occupant Crash Protection. I hope the following discussion answers your questions.

You first asked whether lap/shoulder safety belts are required in a truck with a gross vehicle weight rating greater than 10,000 pounds. 54.3 of the standard, a copy of which is enclosed, sets out the requirements for such trucks. S4.3 permits a manufacturer to install either a lap safety belt, referred to as a Type 1 belt in the standard, or a lap/shoulder belt, referred to as a Type 2 belt, in a heavy truck. At the present time, we do not have any plans to require lap/shoulder belts in heavy trucks. We are taking steps to improve the comfort and convenience of safety belt systems in heavy vehicles. As explained in the attached notice, the agency is currently considering several changes to the standard which would make it easier to use safety belts in heavy vehicles. We expect to issue a final rule on this subject later this year.

If you have any further questions, please let me know.

Sincerely,

Erika Z. Jones Chief Counsel

Ms. Diane K. Steed Administrator National Highway Traffic Safety Administration 400 Seventh Street, S. W. Washington, DC 20590

Reference: Seat Belt Requirements for Trucks with G.V.W.R. of More Than 10,000 Pounds per Motor Vehicle Safety Standard No. 208

Dear Ms. Stead:

I have been asked to respond to a question from one of our employees about seat belt requirements for trucks in the 20,000 pounds G.V.W. range. His question was "Why aren't our medium duty (20,000 lb. G.V.W.) trucks purchased with lap and shoulder belts like those required in cars?"

Apparently they are not required by Standard No. 208 and are not offered by the manufacturers.

I would appreciate it if you could tell me if our interpretation of Standard No. 208 is correct. I would also like to know if there are any plans to require lap and shoulder belts in this size vehicle.

Your assistance is appreciated.

Yours very truly,

Alvin A. Leach, Manager Corporate Transportation Services