Interpretation ID: 1985-02.41

TYPE: INTERPRETATION-NHTSA

DATE: 06/10/85

FROM: AUTHOR UNAVAILABLE; Jeffrey R. Miller; NHTSA

TO: Russ L. Bomhoff

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of April 18, 1985, concerning the applicability of our safety standards to a passenger van you are designing. Specifically, you asked whether you can install a stationary, side-facing passenger seat with lap safety belts. As discussed below, you can use such a seat with a lap safety belt, but its use would be affected by Federal Motor Vehicle Safety Standard Nos. 207, Seating Systems, 208, Occupant Crash Protection, 209, Seat Belt Assemblies, and 210, Seat Belt Assembly Anchorages. A copy of each of those standards is enclosed.

Standard No. 207 specifies performance requirements for seats, their attachment assemblies, and their installation, to minimize the possibility of seat failure resulting from crash forces. This standard is applicable to seats installed in vehicles including vans, but section 4.2 of Standard No. 207 excludes side-facing seats from the general seat strength requirements of the standard. However, there are other requirements in the standard which may apply to side-facing seats. For example, paragraph S4.3 requires a restraining device if the seat has a hinged or folding seat or seat back.

Standard No. 208 sets requirements for the installation of safety belts in motor vehicles. You stated that the vehicle you are designing is a passenger van that carries under 10 passengers. If your vehicle carries a total of 10 persons (9 passengers and a driver) it would be considered either a multipurpose passenger vehicle (MPV), if it is manufactured on a truck chassis or has special features for occasional off-road use, or a passenger car.

If your vehicle is a passenger car, section 4.1.2.3(c) of the standard provides that each designated seating position for rear passengers can have a Type 1 (lap) or Type 2 (lap/shoulder safety belt) that conforms with Standard 209 and the adjustment and latch mechanism requirements of S7.1 and S7.2 of Standard No. 208. If your vehicle is a MPV, then S4.2.2, for MPV's with a GVWR greater than 10,000 pounds or less, or S4.3, for MPV's with a GVWR greater than 10,000 pounds, provides that each designated seating position for rear passengers can have a Type 1 or Type 2 safety belt that conforms to Standard No. 209.

Standard No. 210 sets performance requirements for safety belts anchorages in passenger cars, MPV's, trucks, and buses. The standard exempts side-facing seats from its strength requirements specified in S4.2, but all other requirements of the standard apply to side-facing seats. We strongly recommend that belt anchorages for side-facing seats be of at least equivalent strength to the anchorages for forward and rearward facing seats, since the strength specifications are only minimum performance requirements.

ENCLS.

PRECISION PATTERN INC.

April 18, 1985

Office of Chief Counsel NHTSA

Dear Sir:

This letter is a request for a ruling concerning a safety standard as applicable to passenger van seating. Specifically, I need to know if putting a stationary side facing seat, with lap seat belts is legal and acceptable.

This side facing seat would be equipped with lap seat belts if necessary. It would be located at the rear of the vehicle, behind the drivers seat.

The vehicles in question are for under 10 passengers, and are of 15', 17', and 20' lengths.

We are in the middle of a design project on this and your prompt attention to this matter would be greatly appreciated. Please call 316/ 942-0905 if you have any questions. Thank you.

Mr. William Smith in your engineering dept. requested that I consult you for a permanent ruling. His interpretation of the rules would allow the use of this side facing seat.

Russ L. Bomhoff

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