ID: nht94-2.22

TYPE: Interpretation-NHTSA

DATE: April 7, 1994

FROM: John Womack -- Acting Chief Counsel, NHTSA

TO: Steve J. Brooks -- Program Manager, IAD West Coast, Inc. (CA)

TITLE: None

ATTACHMT: Attached to letter dated 12/8/93 from Steve J. Brooks to Office of Chief Council, NHTSA (OCC 9443)

TEXT:

This responds to your letter asking about the operation and classification of a commercial vehicle you wish to manufacture. The vehicle will carry fewer than 10 passengers and its GVWR will be 11,500 pounds. You were particularly interested in the type of operator's license that would be required of the driver.

Driver licensing requirements for vehicle operators are determined by state law. Since the vehicle's GVWR will be less than 26,000 lbs, and the vehicle will presumably be designed to carry fewer than 15 passengers, the driver will not be required, under the Federal Highway Administration's (FHWA's) Commercial Driver Licensing (CDL) regulations, 49 CFR part 383, to qualify for a commercial driver license. However, some states require that drivers obtain a commercial driver license to drive vehicles tha t have lower GVWRs. The driver licensing requirements of the state in which the vehicle is registered, will apply. For more information about the CDL requirements, you can contact the FHWA Chief Counsel's office at (202) 366-0834.

Vehicle classification is relevant for the regulations and standards of our agency. The National Traffic and Motor Vehicle Safety Act authorizes the National Highway Traffic Safety Administration (NHTSA) to issue Federal motor vehicle safety standards ( FMVSSs) for new motor vehicles and motor vehicle equipment. Each FMVSS for motor vehicles applies to one or more particular types of vehicles, e.g., a standard might apply to passenger cars, buses, trucks, and/or trailers.

To determine which FMVSSs apply to their vehicles, manufacturers classify their vehicles using the definitions in 49 CFR part 571.3 of NHTSA's regulations. Under part 571.3 (copy enclosed), your vehicle, which you said is built in a bus/truck chassis, ap pears to be a "truck" or a "multipurpose passenger vehicle." Under part 567, a manufacturer must state the vehicle classification on the vehicle's certification label and certify that its motor vehicle complies with all applicable FMVSSs. NHTSA may tak e issue with a manufacturer's vehicle classification in an enforcement proceeding if the agency does not agree with the manufacturer's classification.

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

ID: nht94-2.23

TYPE: Interpretation-NHTSA

DATE: April 7, 1994

FROM: John Womack -- Acting Chief Counsel, NHTSA

TO: Robert Matulich (Seattle, WA)

TITLE: None

ATTACHMT: Attached to letter dated 12/15/93 (est) from Robert Matulich to Office of Chief Council, NHTSA (OCC 9449)

TEXT:

This responds to your letter requesting information about Federal requirements applicable to your product. According to promotional literature that accompanied your letter, your "Clear Vu Mirror" is an attachment to exterior mirrors that clears raindrop s, dust, and mist, thus making a mirror "virtually self-cleaning." I am pleased to explain the applicability of our regulations to your product.

By way of background information, the National Highway Traffic Safety Administration (NHTSA) is authorized to issue Federal Motor Vehicle Safety Standards (FMVSSs) that set performance requirements for new motor vehicles and items of motor vehicle equipm ent. NHTSA does not, however, approve or certify any vehicles or items of equipment. Instead, the National Traffic and Motor Vehicle Safety Act ("Safety Act") establishes a "self-certification" process under which each manufacturer is responsible for c ertifying that its products meet all applicable FMVSSs.

NHTSA currently has no FMVSSs that directly apply to the product you plan to manufacture. NHTSA issued an FMVSS for vehicle rearview mirrors (FMVSS No. 111), but the standard applies to new vehicles, and not to aftermarket mirror products. If your prod uct were manufactured and sold as part of a new vehicle, the vehicle would have to be certified as complying with all applicable standards, including Standard No. 111. The standard sets field of view requirements for new motor vehicles, and your product would have to be mounted on a new vehicle such that it does not block the field of view required by FMVSS No. 111. However, since Standard No. 111 applies only to new vehicles, it does not apply to your product.

I note, however, that there are other Federal requirements that indirectly affect you and your product. Under the Safety Act, your product is considered to be an item of motor vehicle equipment. As a manufacturer of motor vehicle equipment, you are sub ject to the requirements in SS151-159 of the Safety Act concerning the recall and remedy of products with safety related defects. I have enclosed an information sheet that briefly describes those responsibilities. In the event that you or NHTSA determi nes that your product contains a safety-related defect, you would be responsible for notifying purchasers of the defective equipment and remedying the problem free of charge.

In addition, manufacturers, distributors, dealers, and motor vehicle repair businesses are subject to S108(a)(2)(A) of the Safety Act, which states: "No manufacturer, distributor, dealer, or motor vehicle repair business shall knowingly render inoperati ve ... any device or element of design installed on or in a motor vehicle or item of motor vehicle equipment in compliance with an applicable Federal motor vehicle safety standard ...." It is conceivable that your product, when placed on a vehicle's ext erior mirror, could "render

inoperative" the vehicle's ability to comply with FMVSS No. 111. Persons in the aforementioned categories cannot install your product if it blocks the field-of-view required by FMVSS No. 111, or otherwise caused the vehicle to no longer comply with Stan dard No. 111.

The "render inoperative" prohibition of S108(a)(2)(A) does not apply to the actions of vehicle owners in adding to or otherwise modifying their vehicles or items of motor vehicle equipment. Thus, if your product were placed on an exterior mirror by the vehicle owner, the render inoperative provision would not apply. Nevertheless, NHTSA urges vehicle owners not to degrade the safety of any system or device on their vehicles, including the safety of their rearview mirrors.

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

ID: nht94-2.24

TYPE: Interpretation-NHTSA

DATE: April 7, 1994

FROM: John A. Boehner -- Congress of the United States, House of Representatives

TO: Jackie Lowey -- Director, Congressional Affairs, DOT

TITLE: None

ATTACHMT: Attached to letter dated 6/25/94 Est from John Womack to John A. Boehner (A42; Std. 108; VSA S102(a)(2)(A)) and letter dated 3/25/94 from James Ackley, Carol Baumhauer and Krista D. Subler to John A. Boehner

TEXT:

The enclosed correspondence requesting permission to use two unassigned colors was sent to me by Mr. John Cail and Mr. James Ackley.

I would greatly appreciate you providing my Hamilton office with the appropriate information so that I may reply to my constituent's inquiry.

If I may provide additional information, please do not hesitate to contact me.

Attachment

C & L Safety Products Unlimited Eaton, Ohio

The Honorable John A. Boehner (R-Ohio) 1020 Longworth House Building Washington, D.C. 20510

Dear Mr. Boehner,

We are writing to request the assistance of your office, or your personal assistance, in obtaining Department of Transportation approval and color code designation on our, LIFE LITES system. Our firm has secured a patent, foreign trade license and comple ted testing with the Ohio State University, and is ready to begin producing the device.

C & L Safety Products currently has a plastics firm and lighting manufacturer within your district to begin production, as well as, several organizations who have committed to purchase the final product. We feel normal, or abnormal delays, in securing ap proval for the device could adversely impact the economic development of your voting area. Rapid approval would permit you to utilize our firm as an example, particularly in an election environment, of the assistance you can provide to those considering southwest Ohio as a site for future business. Additionally, we are prepared to utilize our public relations firm in contacting other organizations with the details of any assistance provided by you in this matter.

Sue Clark, of your Hamilton office, has been working with us, and has all the details of efforts made to date in securing approval, and has been greatly supportive in moving through the Department of Transportation process.

We have taken the liberty of enclosing a local and national press article explaining the purpose of the device, as well as, copies of the patent and foreign trade permit. Should there be any questions, please call us, to reduce the delays associated wit h mailed correspondence. Best wishes for continued success.

Sincerely,

John Cail Sr. James Lipps

3/29/94

ID: nht94-2.25

TYPE: Interpretation-NHTSA

DATE: April 8, 1994

FROM: John Womack -- Acting Chief Counsel, NHTSA

TO: Daniel T. Mason -- Product Development Engineer, Avery Dennison - Automotive Division (Troy, MI)

TITLE: None

ATTACHMT: Attached to letter dated 2/14/94 from Daniel T. Mason to Barbara Gray (OCC 9807)

TEXT:

This responds to your request for an interpretation of labeling requirements under 49 CFR part 541 Federal motor vehicle theft prevention standard. Your letter has been referred to my office for a reply. You asked whether a label that leaves a fluoresc ent "footprint" of a vehicle identification number (VIN) on a vehicle part, complies with section 541.5(d)(1)(v)(B) of part 541. The answer is yes.

Section 541.5(d)(1)(v)(B) requires that if a theft program label is removed from a vehicle part, "residual parts of the label" be left in the area of the part where the label was affixed. The residual parts, also known as "footprints," provide investiga tors evidence that a label was originally present. "Footprint" requirements for theft labels were discussed in the preamble to the final rule establishing 49 CFR part 541 (See 50 FR 43166, at 43174; October 24, 1985):

... this standard requires only that removal of the labels must leave residual parts of the label ... , on the part, and that these residual parts must be discernible by trained investigators. For purposes of this requirement, "disce rnible" does not mean that residual parts must be visible under natural light. (50 FR 43174).

In your letter, you stated that Avery Dennison's VIN marked labels have a fluorescent agent that transfers onto vehicle parts when the label is applied. If the label is removed, and the formerly labelled area is viewed under an ultraviolet light, a repro duction of the VIN is visible. If the labels, when removed, leave "residual part(s) of the label ... on the part" that is "discernible" under ultraviolet light, the Avery Dennison label would fulfill section 541.5(d)(1)(v)(B).

I hope this responds to your question. If you have any further questions, please contact Dorothy Nakama of my staff at (202) 366-2992.

ID: nht94-2.26

TYPE: Interpretation-NHTSA

DATE: April 8, 1994

FROM: John Womack -- Acting Chief Counsel, NHTSA

TO: Thomas Turner -- Manager, Engineering Services, Blue Bird Body Company (Fort Valley, GA)

TITLE: None

ATTACHMT: Attached to letter dated 2/15/94 from Thomas D. Turner to George Entwistle (OCC 9696); Also attached to letter dated 1/26/83 from Frank Berndt to Thomas D. Turner

TEXT:

This responds to your letter to NHTSA's Office of Safety Compliance requesting an interpretation of the conspicuity requirements in Standard No. 131, School Bus Pedestrian Safety Devices. This letter confirms your understanding that a reflectorized stop signal arm that fully complies with the reflectorization requirements in S5.3.1 complies with S5.3, regardless of whether a stop signal arm is equipped with strobe lights that do not comply with S5.3.2.

As you are aware, S5.3 conspicuity states "The stop signal arm shall comply with either S5.3.1 or S5.3.2, or both." Section S5.3.1 sets forth requirements addressing reflectorization, and S5.3.2, which references S6.2, sets forth requirements addressing flashing lamps. Section S6.2.2 specifies a stop signal arm's flash rate.

You explained that some of the stop signal arms that you install fully comply with the reflectorization requirements in S5.3.1. However, these stop signal arms are also equipped with strobe lights that do not comply with S5.3.2 because they do not comp ly with the flash rate requirements in S6.2.2.

As we noted above, compliance with the conspicuity requirements in S5.3 can be established EITHER by complying with the reflectorization requirements in S5.3.1 OR the flashing light requirements in S5.3.2. (emphasis added) Since the stop signal arms in question comply with the reflectorization requirements, they comply with the conspicuity requirements and need not comply with the flashing light requirements.

I hope this information is helpful. If you have any questions about NHTSA's safety standards, please feel free to contact Marvin Shaw at this address or by telephone at (202) 366-2992.

ID: nht94-2.27

TYPE: Interpretation-NHTSA

DATE: April 8, 1994

FROM: John Womack -- Acting Chief Counsel, NHTSA

TO: Perry McGlothan -- Quality Assurance Test Specialist, Century Products Company (Macedonia, OH)

TITLE: None

ATTACHMT: Attached to letter dated 12/15/93 from Perry McGlothan to Chief Counsel, NHTSA (OCC 9495)

TEXT:

This responds to your letter to me about the head impact protection and protrusion limitation requirements of Federal Motor Vehicle Safety Standard (FMVSS) No. 213, Child Restraint Systems. We received under separate cover the three child seats you sent for illustration purposes, samples of Models 4560, 4590 and the STE 1000.

You discuss in your letter a new method you would like to use to attach the head impact protection foam to the child restraint shell. The foam would be attached to the shell by means of two push-in pins, each 1/2 inch in length and with a 3/4 inch diame ter head, as distinguished from the padding being glued to the shell as in the past. You stated that this change would better secure the foam padding to the shell and help your manufacturing process. You asked us whether the new method would meet the h ead impact protection requirement of S5.2.3 (for restraints recommended for children weighing less than 20 pounds) and the protrusion limitations of S5.2.4.

As you know, the National Traffic and Motor Vehicle Safety Act establishes a self-certification system under which manufacturers are responsible for ensuring that their products comply with all applicable FMVSSs. We do not approve, endorse, or give assu rances of compliance of any product. NHTSA may examine the manufacturer's certification in the course of any enforcement action. In response to manufacturers' requests for interpretations of the FMVSS's, we try, to the extent possible, to provide infor mation that will help them make their determinations of compliance. However, these responses are based on information provided by the manufacturer, and it subject to the findings of actual compliance testing by the agency. Should the agency, in the fut ure, examine production units of these models and detect an apparent noncompliance or defect, those results will control.

You first inquire, "Please advise as to compression deflection," which we understand as asking whether S5.2.3.2 would permit you to secure the foam with the pins. (*1) S5.2.3.2 states that each system surface, except for protrusions that comply with S5 .2.4, which is contactable by a dummy head must be covered with slow recovery, energy absorbing material with specified characteristics. As explained in the next paragraph, the pins we examined appear to satisfy S5.2.4. Further, the pins might not be c ontactable by the dummy head in Standard 213's dynamic test. However, whether they are contactable can only be determined in the standard's dynamic test.

S5.2.4 requires that any portion of a rigid structural component within or underlying a contactable surface, or any portion of a child restraint system surface that is subject to S5.2.3 shall meet specified limits on height and radius of exposed edge. B ased on our visual inspection, the pins we saw appear

to be within those limits. Again, however, the Vehicle Safety Act places the responsibility for determining compliance in the first instance on you, the manufacturer of the child restraint.

We still have the three seats that you sent us. We plan to dispose of them unless we hear from you.

I hope this information is helpful to you. Should you have any further questions or need further information, please feel free to contact Walter Myers of this office at this address or at (202) 366-2992.

* 1 We cannot tell you whether the foam padding would satisfy S5.2.3 of Standard 213. The compression deflection resistance and thickness of the material can only be determined in a compliance laboratory, using the laboratory procedures described in th e standard.

ID: nht94-2.28

TYPE: Interpretation-NHTSA

DATE: April 8, 1994

FROM: John Womack -- Acting Chief Counsel, NHTSA

TO: Derrick Barker -- John Martin Designs (Stourbridge, West Midlands)

TITLE: None

ATTACHMT: Attached to letter dated 12/22/93 from Derrick Barker to Mary Versilles (Versailles)

TEXT:

This responds to your letter concerning the buckle release requirement of Federal Motor Vehicle Safety Standard No. 213, "Child Restraint Systems." I apologize for the delay in responding.

You asked for the "tensile load requirements for the buckle and tongue." There is no specific requirement in Standard 213 for the tensile force that a child restraint buckle must withstand. Instead, the buckle must maintain its integrity when the chil d restraint is subjected to a simulated frontal impact at 30 mph with either a six-month-old (17 pounds (lbs.)) or three-year-old (33 lbs.) sized dummy restrained in the car seat. At the conclusion of the simulated impact, the force required to depress the latch button to release the buckle is measured and must be 16 lbs. or less.

You also asked for a copy of Procedure D of the American Society for Testing and Materials Standard D756-78. Section S5.4.2 of FMVSS No. 213 sets forth those requirements by making reference to section S4.3(b) of FMVSS No. 209. which, in turn, leads to the reference to Procedure D of ASTM D756-78. The material you requested is enclosed.

In addition, you asked for a list of laboratories that test child safety seats and buckles. NHTSA does not endorse particular test laboratories. However, I can provide you with a list of laboratories we are aware of that conduct child restraint complia nce tests. There may be other laboratories that can test child safety seats and buckles.

Please contact Ms. Deirdre Fujita of my staff if you have further questions.

LABORATORIES CONDUCTING CHILD RESTRAINT COMPLIANCE TESTS (Partial List - Addresses current as of Dec. 1993) CALSPAN CORPORATION (CAL) 4455 Genesee St. Buffalo, NY 14225 Phone: 716-632-7500 FAX: 716-631-6843

COMMERCIAL TESTING CO. (CTC) (Flammability testing) 1215 S. Hamilton Street Dalton, GA 30722-0985 Phone: 404-278-3935 FAX: 404-278-3936 DETROIT TESTING LABORATORY, INC (DTL) 7111 E. Eleven Mile Road Warren, Mi 48092-0869 Phone: 313-754-9000 FAX: 313-754-9045

MGA RESEARCH CORPORATION (MGA) 12790 Main Road P.O. Box 71 Akron, NY 14001-0071 Phone: 716-542-5515 FAX: 716-542-4437

MGA PROVING GROUNDS 5000 Warren Road Burlington, WI 53105 Phone: 414-763-2705 FAX: 414-763-0934

MOBILITY SYSTEMS & EQUIP. CO. (MSE) 19867 Cajon Blvd San Bernadino, CA 92407 Phone: 909-887-1938 FAX: 909-887-5937

MOBILITY SYSTEMS & EQUIP. CO. (MAIN OFFICE) 9920 LaCienega Blvd., Suite 708 Inglewood, CA 90301 Phone: 310-641-3606 FAX: 310-641 -1930

TRANSPORTATION RESEARCH CENTER OF OHIO (TRC) 10820 State Route 347 P.O. Box B67 East Liberty, OH 43319 Phone: 513-666-2011 FAX: 513-666-5066

UNITED STATES TESTING CO. (UST) - (Flammability testing) Engineering Services Division 291 Fairfield Avenue Fairfield, NJ 07004 Phone: 201-575-5252 FAX: 201-575-8271

UNITED STATES TESTING CO. (MAIN OFFICE) 1415 Park Avenue Hoboken, NJ 07030 Phone: 201-792-2400 FAX: 201-656-0636

UNIVERSITY OF MICHIGAN TRANSPORTATION RESEARCH INSTITUTE (UMTRI) 2901 Baxter Road Ann Arbor, MI 48109-2150 Phone: 313-936-1103

ID: nht94-2.29

TYPE: Interpretation-NHTSA

DATE: April 11, 1994

FROM: John Womack -- Acting Chief Counsel, NHTSA

TO: Lawrence A. Beyer, Esq.

TITLE: None

ATTACHMT: Attached to fax/letter dated 2/14/94 from Lawrence A. Beyer to Z. Taylor Vinson (OCC 9677)

TEXT:

This is in reply to your FAX of February 14, 1994, to Taylor Vinson of this Office, relating to a policy of the Office of Vehicle Safety Compliance (OVSC) regarding importation of vehicles from Canada.

Under this policy, and because of the close congruence of the Federal motor vehicle safety standards of both the U.S. and Canada, OVSC has, in essence, waived the requirement for bond and entry through the registered importer process if the Canadian vehi cle is accompanied by a letter from the vehicle manufacturer stating that the vehicle was manufactured to comply with the U.S. standards, except for minor labelling variations. You state that this policy has been restricted to personally owned vehicles and does not allow "importations of vehicles by corporations for their corporation's personal use." Instead, these vehicles must be entered under bond and conformance verified or achieved by a registered importer. You state that you do not understand t he distinction OVSC makes between individual personal use and corporate personal use.

Under the Imported Vehicle Safety Compliance Act of 1988, as a general matter, a noncomplying vehicle may enter the United States permanently only if it is imported by a registered importer who brings it into compliance. However, an exception is made by 15 U.S.C. 1397(f)(1)(B) which allows importation by a person other than a registered importer if that person has a conformance contract with a registered importer and if the vehicle is imported "for personal use, and not for purposes of resale, by any i ndividual (other than an individual described in subsections (g) and (h)). . . ." The term "individual" refers to a human being and not a corporate person. Therefore, the Act distinguishes both as to whether an importation is for personal use AND wheth er the importer is an individual or a corporation.

I hope that this answers your question.

ID: nht94-2.3

TYPE: Interpretation-NHTSA

DATE: March 28, 1994

FROM: John Womack -- Acting Chief Counsel, NHTSA

TO: Richard Kreutziger -- Executive Director, New York State Bus Distributor Association, Inc.

TITLE: None

ATTACHMT: Attached to faxes dated 2/14/94 and 1/12/94 from Richard Kreutziger to Walter Myers (OCC 9559); Also attached to letter dated 2/20/87 from Erika Z. Jones to Martin V. Chauvin

TEXT:

This responds to your Fax of January 12, 1994, requesting an information on the extent to which a state can adopt requirements for school buses which exceed the Federal motor vehicle safety standards. This also responds to your FAX of February 14, 1994, requesting an explanation of the location requirements for a side emergency door exit in Standard No. 217, Bus Emergency Exits and Window Retention and Release (as amended at 57 FR 49413; November 2, 1992).

Your January 12, 1994 FAX requested clarification of when a state could impose requirements on school buses which exceeded the requirements of the Federal motor vehicle safety standards (FMVSS). Specifically, you asked whether the state could impose suc h requirements on (1) a public school and (2) a contractor providing transportation for a public school. Section 103(d) of the National Traffic and Motor Vehicle Safety Act (the Safety Act; 15 U.S.C. 1392(d)) provides that:

Whenever a Federal motor vehicle safety standard ... is in effect, no State or political subdivision of a State shall have any authority either to establish, or to continue in effect, with respect to any motor vehicle or item of motor vehicle equipment any safety standard applicable to the same aspect of performance of such vehicle or item of equipment which is not identical to the Federal standard. Nothing in this section shall be construed to prevent ... any State o r political subdivision thereof from establishing a safety requirement applicable to motor vehicles or motor vehicle equipment procured for its own use if such requirement imposes a higher standard than that required to comply with th e otherwise applicable Federal standard.

Section 103 (d) preempts state requirements for school buses covering the same aspect of performance as an applicable FMVSS that are different from the applicable FMVSS, except to the extent that the requirements impose a higher level of performance and apply only to vehicles procured for the State's use. A state law imposing higher requirements would be preempted under S103(d) to the extent that the law requires ALL school buses manufactured for use in the state to comply with the law. The law would n ot be preempted to the extent that it applies to public school buses. In addition, the agency has previously interpreted the phrase "vehicles procured for (the State's) own use" to include public school buses and school buses operated and owned by a pri vate contractor under contract to transport children to and from public school. See, for example, February 20, 1987 letter to Mr. Martin Chauvin (copy enclosed).

Your February 14, 1994 FAX asked whether the November 2 final rule permits a right side emergency exit door to be to the rear of the passenger compartment.

The answer is yes. Except for a left side emergency exit door installed as the first additional emergency exit on a bus with a rear emergency door, there are no fore and aft location requirements for side emergency exit doors. I have attached for your i nformation an appendix which lists all the location requirements for additional emergency exits.

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

(Appendix omitted.)

ID: nht94-2.30

TYPE: INTERPRETATION-NHTSA

DATE: April 11, 1994

FROM: David Huff -- Co. Chairperson Special Transportation, Central Missouri State University

TO: Charles Holt -- NHTSA

TITLE: Wheelchair Restraint Standards Clarification

ATTACHMT: Attachment dated 8/14/94: Letter from John Womack to David Huff (Stds. 209 & 222)

TEXT: The Twelfth National Conference on School Transportation, 1995 Standards for Special Needs Bus Body Committee is currently working on appropriate standards for wheelchair and occupant restraint systems. During our research, we have encountered a situati on we feel requires clarification by your office.

Wheelchair securement anchorages as defined in FMUSS 222, $ 5.4.1.1 through $ 5.4.1.3 requires that the anchorage(s) withstand certain force. Paragraph $ 5.4.1.3 indicates when more than one securement device share a common anchorage, the anchorage shal l be capable of withstanding a force of 13,344 newtons multiplied by the number of securement devices sharing that anchorage. We agree with this requirement.

Wheelchair securement devices as indicated in paragraph $ 5.4.2, if incorporating webbing or strap, shall comply with the requirements of type 1 safety belt systems in $ 4.2, $ 4.3 and $ 4.4(a) of FMUSS 209, Seat Belt Assemblies.

Many of the wheelchair and occupant restraint systems use an Integrated occupant restraint system which is anchored in series with the wheelchair securement device, such that, the lap belt anchors to the wheelchair securement near the wheelchair seat.

Our concern is that the webbing or strap for the wheelchair securement device in the integrated system has not been addressed in the amendments to FMUSS 222. It is our feeling that the wheelchair securement device webbing or strap on the integrated syst em should be required to withstand twice the normal load indicated in FMUSS 289, since this webbing or strap is actually securing both the rear of the wheelchair and the occupant simultaneously.

Several manufacturer's adjustment hardware is designed in such a manner that the webbing or strap is doubled in order to remove slack from the securement device. However, there are others who use only a single webbing for this purpose.

Please advice us of your understanding or interpretation of the load requirements for the webbing or strap used in the integrated systems. This information is needed as soon as possible so we may continue drafting our proposed standards.

Thank you for your assistance.