Interpretation ID: aiam3526
Specifications Manager
Indiana Mills & Manufacturing
Inc.
120 West Main Street
Carmel
IN 46032;
Dear Mr. Lawler: This responds to your recent letter asking whether the requirements o paragraph S7.1.1.3 of Safety Standard No. 208, *Occupant Crash Protection*, apply to motor homes and school buses with a GVWR of 10,000 pounds or less. It is your assumption that only those vehicle applications which must have seat belt assemblies meeting S7.1 generally are required to have emergency locking retractors on lap belts.; Your interpretation is incorrect. It is true that belt assemblie installed pursuant to S4.2.1.2 are not required to comply with paragraph S7.1.1 of Standard No. 208, since that paragraph states that it is applicable to lap belts installed pursuant to S4.1.1 and S4.1.2. However, paragraph S7.1.1.3 is not so limited. It states that:; >>>A lap belt installed at any front outboard designated seatin position in a vehicle manufactured on or after September 1, 1982, shall meet the requirements of this section by means of an emergency-locking retractor that conforms to Standard No. 209.<<<; This means that S7.1.1.3 applies to all lap belts installed in an vehicle in compliance with the standard, including belts installed under S4.2.1.2. Therefore, both motor homes and school buses with a GVWR of 10,000 pounds or less would have to comply with the requirement.; Sincerely, Frank Berndt, Chief Counsel