Gordon Bailey, President

Precision Coach Inc.

22677-76B Crescent

Langley, British Columbia V1M 2J8


Dear Mr. Bailey:

This responds to your request for an interpretation as to which National Highway Traffic Safety Administration (NHTSA) requirements would apply to hospital beds in an intensive care unit on wheels. Our answer is provided below.

You explain that your company will be the final stage manufacturer of a vehicle that incorporates a 45 ft. Prevost bus conversion shell. Your plan is to complete the interior of the conversion shell into a motor home for handicapped and bed-ridden persons. You asked a question concerning the safety of persons who will be riding in forward facing permanently fastened hospital beds.

There will be a maximum of two hospital beds in each vehicle. You plan to modify the two beds by welding flanges to the 4 legs that currently have wheels and adding extra braces that will connect to the bed at the upper frame area by the pillow end and run at a 45 degree angle to the floor where they will be bolted through the floor as with the other four legs. You noted that hospital beds tilt and indicated that, when traveling, the occupant will be riding in a flat or forward reclining position. You stated that this situation compares closely to an ambulance carrying a patient in one of its cots while traveling. You stated that your initial idea for the securing of the occupant is to install a harness system for the upper half of the bed.

You wish to know [w]hat requirements are needed to satisfy [NHTSAs] regulations.

In a telephone conversation, you informed Dorothy Nakama of my staff that you have a potential customer in the United States. The vehicle at issue is intended to be, in effect, an intensive care unit on wheels, to accommodate persons who will not be able to travel by other means. You stated that the maximum forward reclining position on a hospital

bed is 45 degrees. You further stated that the vehicle will not be able to be driven by a person in one of the hospital bed positions, but will have a drivers seat and a front passenger occupant seat.

By way of background, NHTSA issues Federal motor vehicle safety standards for motor vehicles and motor vehicle equipment. We do not provide approvals of motor vehicles or motor vehicle equipment. Instead, manufacturers are required by statute to certify that their vehicles and equipment comply with applicable requirements.

In this letter, we are addressing only the issue of whether any of our standards apply to the hospital beds in the vehicle you describe. We note that our standards include, among other things, requirements for such things as seat strength, seat belts, and seat belt anchorages.

As the requirements for those items apply to designated seating positions, their applicability to the beds is dependent upon whether the beds are considered to be designated seating positions under our regulations. The term designated seating position is defined at 49 CFR Part 571.3 as:

any plan view location capable of accommodating a person at least as large as a 5th percentile adult female, if the overall seat configuration and design and vehicle design is such that the position is likely to be used as a seating position while the vehicle is in motion,

Particularly given the maximum forward reclining position for the hospital beds, it is our view that they do not provide seating and would therefore not be considered designated seating positions. Accordingly, because the beds are not designated seating positions, neither our standard concerning seat strength nor our standard requiring seat belts at various locations would apply to them.

We do not have any information concerning the safety of hospital beds in motor vehicles. However, you may wish to review the U.S. General Services Administrations specification that applies to ambulances purchased by the U.S. Federal Government, Federal Specification for the Star-of-Life Ambulance, KKK-A-1822E. A copy of this specification is enclosed. We encourage you to continue to evaluate ways of ensuring the securement and structural integrity of the hospital beds in the event of a crash, and of appropriately restraining the occupants who would be riding in the hospital beds.

We also note that State law may address requirements for motor vehicles that are equipped with hospital beds and are registered or used in a State, as well as rules concerning passengers occupying available recumbent sleeping areas within a moving vehicle. You should consult the laws of the individual States in which your vehicles might operate for further information and guidance.

Finally, while we understand your vehicle to be intended for day-to-day or recreational transport of bed-ridden or otherwise infirmed passengers, we should strongly caution against the consideration or use of this vehicle as a substitute for ambulance care and transportation as necessary for emergency needs or intensive care individuals.

I hope this information is helpful. If you have any further questions, please contact Dorothy Nakama at (202) 366-2992.


Anthony M. Cooke

Chief Counsel