Interpretation ID: nht92-8.25

DATE: March 16, 1992

FROM: Paul Jackson Rice -- Chief Counsel, NHTSA

TO: Jeff Ruff -- Director of Fleet / Government Sales, The Braun Corporation

TITLE: None

ATTACHMT: Attached to letter dated 2/10/92 from Jeff Ruff to Office of the Chief Counsel, NHTSA (OCC 6977)

TEXT:

This responds to your letter of February 10, 1992 requesting advice regarding the location of the upper anchorage for the front passenger seat shoulder belt.

By now, you should have received our reply (dated February 14, 1992) to your previous letter (dated October 30, 1991). In that letter, I explained that NHTSA will not conduct any crash testing of vehicles modified for operation by persons with disabilities while the agency reviews the petition from the Recreation Vehicle Industry Association to exclude these vehicle from the dynamic crash test requirement. Because this is now a pending rulemaking, the agency cannot discuss what requirements the agency will propose for these vehicles prior to the publication of the notice of proposed rulemaking (NPRM). However, as explained in our previous letter, NHTSA is aware of the need of manufacturers such as yourself and your customers to have this matter addressed as soon as possible. Therefore, the agency is proceeding with preparation and publication of the NPRM as quickly as possible.

I hope you find this information helpful. If you have any other questions, please contact Mary Versailles of my staff at this address or by phone at (202) 366-2992.