Interpretation ID: nht94-3.42
TYPE: INTERPRETATION-NHTSA
DATE: June 21, 1994
FROM: Ralph Harpster -- Laguna Mfg, Inc., Turlock, CA
TO: Office of the Chief Counsel, NHTSA
TITLE: NONE
ATTACHMT: Attached to letter dated 9-15-94 from John Womack to Ralph Harpster (A42; STD. 208)
TEXT: I have been referred to your office for clarification of a program that utilizes the retro-fitting of seat belts in the rear of police vehicles.
Our company manufacturers a replacement rear seat used for the transport of prisoners in police cars. Police vehicles face special needs in the equipment they use and the methods they use to transport arrestees.
As you can well imagine, a great number of persons placed in the rear of a police car, under arrest, are not co-operative, nor do they particularly wish to go to jail, therefore, it is of significant importance that they be solidly restrained and unable to get loose in the rear of the vehicle, for obvious reasons.
Unfortunately the seat belt system used by the car manufacturer, while adequate to the task in a collision, will not restrain the prisoner under transport conditions due to the inertia reel retractor system. This allows the person belted in to exercise great range of motion and thus they can extricate themselves from the belt system. They can not only cause a great deal of damage to the vehicle, themselves and the police officer in an attempt to kick out the windows and escape, but can expose themselv es to a significant risk of injury should a collision occur while they are out of the belt.
In an effort to simplify the transport process, we furnish a molded seat that accomplishes several tasks. First, the seat will hold a prisoner upright and in place due to its molded configuration. Secondly, the seat eliminates the ability of the prison er to hide contraband, i.e. drugs, weapons etc. Thirdly the molded seat can be washed or disinfected thus helping a police dept. in its policy to overcome the problems associated with blood borne pathogens. Our query lies in the first task enumerated a bove. We retrofit the car with a seat belt system that overcomes the problem associated with the inertia reel retractor system. In our system we utilize a belt that pulls snugly, in a positive restraint mode and does not use a retractor. When the offi cer places the prisoner in the seat, the belt system is latched in place just as any seat belt would be, then the belt is manually pulled tight and remains in that position until manually released. We use a shoulder lap combination belt for meeting the 3 point fastening criteria, and we use only belts certified to meet M.V.S.S. 209-302. Additionally we use factory seat belt mounting locations. We desire that you review our stated use and render an opinion regarding the use of this system and, if in y our opinion, it fits the criteria established for retrofitting.
I would also, separately, like an opinion if a single shoulder belt could possibly meet any of the requirements. I realize that, like many agencies today, you have to deal with an increasingly heavy workload, but I would be extremely grateful if your of fices could give this the earliest possible consideration as we are trying very hard to do things in the most straight forward and compliant manner that we can.
I will take the liberty of thanking you in advance for any courtesy and consideration you can tender us.