Interpretation ID: nht91-4.46

DATE: July 11, 1991

FROM: Jack Garbo -- President/General Counsel, AVM Products, Inc.

TO: Mary Versailles -- NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 8-14-91 from Paul Jackson Rice to Jack Garbo (A38; Std. 208)

TEXT:

Per our recent telephone conversation, I am writing to get clarification on the issue of whether the three-point seatbelt is required in all middle and rear outboard seating positions in the multipurpose vehicles after September 1, 1991.

My understanding is that the revised FMVSS 208 pertains only to forward facing chairs and sofas, and specifically excludes rearward facing furniture.

My company manufactures a small sofa which is mounted on a quick release track system. This sofa faces rearward and is equipped with two lap seatbelts.

Please let me know if I am interpreting the language of the regulation properly.

Thank you very much for assistance in helping us with this question.