Interpretation ID: aiam3747
Potemkin
21111 South Dixie Highway
Miami
FL 33189;
Dear Mr. Desarro: This is to follow up on your phone conversation with Stephen Oesch o my staff concerning the type of seat belts that must be used in a 1983 converted van that has a sofa.; Paragraph S4.2.2 of Safety Standard No. 208, *Occupant Cras Protection*, (copy enclosed) required trucks and multipurpose passenger vehicles with a gross vehicle weight rating of 10,000 pounds or less to meet the same requirements as passenger cars. This would include the vans in question. Paragraph S4.1.2.3 of the standard specifies that passenger cars must be equipped with a Type 2 seat belt assembly (non-detachable lap and shoulder belt) at each front outboard designated seating position. At all other seating positions, 2 seat belt assembly must be used. Thus, your vans must have Type 2 belts in the two front seats and either Type 2 or Type 1 belts in the rear seating positions, including the sofa. The agency's position regarding seat belts for sofa/beds used in van conversions is more fully explained in the enclosed interpretation letter of March 29, 1983, to Sherrod Vans, Inc.; If you have any further questions, please let me know. Sincerely, Frank Berndt, Chief Counsel