Interpretation ID: nht87-1.92

TYPE: INTERPRETATION-NHTSA

DATE: 06/04/87

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Ms. Robin Bender Stevens

TITLE: FMVSS INTERPRETATION

TEXT:

Ms. Robin Bender Stevens Health Policy and Planning Consultant ECRI 5200 Butler Pike Plymouth Meeting, PA 19462

Dear Ms. Stevens:

Thank you for your letter of March 26, 1987, asking several questions about how our regulations on safety belts would apply to side and rear-facing seats in emergency medical vehicles. I hope the following discussion answers your questions.

You explained in your letter that most emergency medical vehicles have a rear-facing seat that is typically located behind the driver's seat. The photographs you bent with your letter show that in one or the the vehicle designs you photographed, the rear -facing seat appears to be a typical vehicle seat, referred to as a "captain's chair," often used in a van-type vehicle. In the other emergency vehicle design shown in your photographs, there is a rearward-facing, bench-type seat with a padded seat pan a nd back installed directly behind the driver.

You further explained that, depending on the number of stretchers the vehicle is designed to carry, there may be another seating area in the vehicle. In single-stretcher vehicles, there is a squad bench, which your photographs show is a set of storage co mpartments with a padded top, located next to the stretcher. You explained that emergency personnel may bit on the squad bench to attend the the patient while the vehicle is in motion. You further explained that personnel in dual-stretcher vehicles sit o n the empty stretcher to attend to the patient. You said that use of a safety belt in those positions is too restrictive to allow emergency personnel to provide acute care to patients during transport.

Standard No. 208 Occupant Crash Protection, sets requirements for the installation of occupant restraints in motor vehicles. The emergency medical vehicles shown in your photographs would be classified as multipurpose publisher vehicles under our regulat ions since they are designed to carry 10 or fewer persons and are built on a truck chassis. Standard No. 208 requires manufacturer of new multipurpose passenger vehicles to install a safety belt for each designated seating position. Part 571.3 of our reg ulations defines, in part, a designated seating position as:

Any plan view location capable of accommodating a person at least as large as a 5th percentile female, if the overall seat configuration and design and vehicle design is likely to be used as a seating position while the vehicle is in motion, except for a uxiliary seating accommodations such as temporary or folding jump seats.

The agency considers the two types of rearward-facing seats in the emergency medical vehicles you photographed to be designated seating positions. Those seats are designed and built in the same manner as conventional vehicle seats in that they have a pad ded gear pan and a high padded seat back. In fact, the one seat appears to be a conventional "captains chair" which has been mounted in a rearward-facing position. The two rearward-facing seats are also designed to be used on a routine basis by an emerge ncy medical personnel as the vehicle travels to its destination.

In contrast, the agency does not consider a squad bench or a stretcher to be a designated seating position. Neither a squad bench not a stretcher is designed or built in the same manner as a conventional vehicle seat. Although they have the equivalent of a seat pan, they do not have a seat back. Most importantly, both the squad bench and stretcher are meant to be used on a temporary basis as auxiliary seating positions by emergency medical personnel as they provide treatment to a patient. Thus, as an au xiliary seating area, they would not be considered a designated seating position and therefore not subject to the safety belt installation requirement of Standard No. 208.

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

Sincerely,

Erika Z. Jones Chief Counsel

Erika Z. Jones, J.D. Chief Counsel National Highway Traffic Safety Administration Room 5219 400 Seventh Street, S.W. Washington, DC 20590

Dear Ms. Jones

At the suggestion of Steve Oesch, I am writing to you to request a formal interpretation of the agency's regulations regarding seat belts in emergency medical vehicles.

I have discussed with Mr. Oesch my question as to whether the side-and rear-facing seats of emergency medical vehicles require seat belts. Most emergency medical vehicles have a rear-facing seat that is typically located behind the driver's seat. In addi tion, these vehicles may be designed to transport either one or two stretchers. (See the enclosed photograph for examples of single- and dual-stretcher vehicles.) Single-stretcher vehicles have a squad bench next to the stretcher on which emergency pers onnel may be seated to attend to the patient while the vehicle is in motion. Personnel in dual-stretcher vehicles sit on the empty stretcher to attend to the patient. Use of the seat belt in these positions is too restrictive to allow emergency personnel to provide acute care to patients during transport.

It is my understanding that ambulances are categorized as multipurpose passenger vehicles and, as such, must provide seat belts only for designated seating positions. I also understand that seat belts are not required for auxiliary seating positions. The issue, then, is whether side- and rear-facing seats - -including a second stretcher - - in the patient compartment of an emergency medical are considered designated or auxiliary seating positions.

I therefore request a formal interpretation of the agency's regulations regarding the need for seat belts for the side- and rear-facing seats in emergency medical vehicles and the particular need for seat belts for personnel seated in auxiliary seating p osition while the vehicle is in motion.

Sincerely,

Robin Bender Stevens Health Policy and Planning Consultant