Interpretation ID: nht75-5.48

DATE: 07/03/75

FROM: AUTHOR UNAVAILABLE; J. C. Schultz; NHTSA

TO: Sheller-Globe Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This responds to Sheller-Globe's June 16, 1975, request for a statement of the requirements for 1976-model multipurpose passenger vehicles (MPV's) specified by Standard No. 208, Occupant crash protection.

Section S4.3 of the standard sets out the requirements for MPV's with a gross vehicle weight rating (GVWR) or more than 10,000 pounds. These requirements are the same in the future as at present.

Section S4.2 sets out the requirements for MPV's with a GVWR of 10,000 pounds or less (S4.2.1 for vehicles until August 15, 1975, and S4.2.2 for vehicles on or after August 15, 1975 until August 15, 1977). As the standard is presently effective, S4.2.2 will require that most MPV's of 10,000 pounds or less be equipped with the same seat belts and warning systems as presently installed in passenger cars. I have enclosed a copy of those requirements as they were revised October 29, 1974 (40 FR 38380, October 31, 1974). Also enclosed is a Federal Register notice of December 6, 1974, that sets out the associated warning system requirements (40 FR 42692, December 6, 1974). The only MPV's excepted from these requirements are forward control vehicles, convertibles, open-body type vehicles, walk-in van-type trucks, motor homes, and vehicles carrying chassis-mount campers. They will continue to be required to meet the requirements of S4.2.1.2 as presently in effect.

The National Highway Traffic Safety Administration recently proposed that a manufacturer have the option of meeting the requirements of S4.2.1 or S4.2.2 until January 1, 1976. I enclose a copy of that proposal, which includes a preamble discussion of the reasons for this proposal. A final determination will appear in the Federal Register.

Sincerely,

SHELLER-GLOBE CORPORATION Vehicle Planning and Development Center

June 16, 1975

U.S. Department of Transportation National Highway Traffic Safety Administration

Attention: Richard B. Dyson Assistant Chief Counsel

Reference: Federal Motor Vehicle Safety Standard 208 - Occupant Crash Protection

There have been so many changes in the referenced safety standard that it is quite possible for an individual to misinterpret its requirements applicable to a motor vehicle.

As you know, Sheller-Globe Corporation manufacturers School Buses, Motor Homes (Recreational Vehicles) and Professional Vehicles (Funeral Coaches and Ambulances). All of these motor vehicles, except School Buses, fall under the definition of Multipurpose Passenger Vehicles.

The manufacturing divisions of Sheller-Globe Corporation have requested of me direction pertinent to how they are required to comply to safety standard 208 for 1976 model year Multipurpose Passenger Vehicles (M.P.V.'s).

The requirement for certain types of M.P.V.'s after December 31, 1975 was what was specified for passenger cars from September 1, 1973 to August 14, 1975 (Paragraph S4.1.2). However, the requirements of that paragraph have been revised or are proposed for revision.

Could you please direct myself and Sheller-Globe Corporation pertinent to the requirements of Federal Motor Vehicle Safety Standard 208 - Occupant Crash Protection as it will apply to Multipurpose Passenger Vehicles for model year 1976?

Your direction in this matter would be deeply appreciated.

George R. Semark - Manager Vehicle Safety Activities