Interpretation ID: 1982-1.16

TYPE: INTERPRETATION-NHTSA

DATE: 02/17/82

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Indiana Mills & Manufacturing, Inc.

TITLE: FMVSS INTERPRETATION

TEXT:

FEB 17 1982

NOA-30

Mr. William E. Lawler Specifications Manager Indiana Mills & Manufacturing, Inc. 120 West Main Street Carmel, Indiana 46032

Dear Mr. Lawler:

This responds to your recent letter asking whether the requirements of 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 assemblies 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 seating 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 any 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

November 25, 1981

Mr. Frank Berndt, Chief Counsel National Highway Traffic Safety Administration 400 7th Street S.W., Room 5219 Washington, D.C. 20590

Dear Sir:

The Federal Register dated January 8, 1981, carried a final rule amending Standard No. 208 (49-CFR 571.208) which becomes effective September 1, 1982. According to the final rule, the amendment applies to "seat belt assemblies installed in all vehicles with GVWR of 10,000 lbs. or less." The amendment pertains to section 7.1 of the standard.

Most trucks and multi-purpose passenger vehicles covered by S4.2.2 must comply with one of the sections under S4.1.2, each of which refers to S7.1. However, there are several exceptions listed which may meet the requirements of S4.2.1.2.; the later contains no reference to S7.1.

It is our interpretation that it is only those vehicle applications which require seat belt assemblies meeting S7.1. that are required to have an emergency-locking retractor on a lap belt installed in the front outboard designated seating positions.

Please send us your written explanation of the intent of S7.1.1.3. of Standard No. 208, and specifically it's application to motor homes and school buses with a "GVWR of 10,000 lbs. or less."

Thank you for your help.

Yours very truly,

William E. Lawler Specifications Manager

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