Interpretation ID: 3115yy
President/General Counsel
AVM Products, Inc.
2333 Delante St.
Fort Worth, TX 76117
Dear Mr. Garbo:
This responds to your letter of July 11, 1991, requesting clarification of Standard No. 208. Specifically, you asked "whether the three-point seatbelt is required in all middle and rear outboard seating positions in the multipurpose vehicles after September 1, 1991." Specifically, you requested verification of your interpretation that these requirements apply only to forward-facing seating, and not rearward-facing seating. Your interpretation regarding rearward-facing seats is correct.
Beginning September 1, 1991, multipurpose passenger vehicles must have lap/shoulder belts at every forward-facing rear outboard designated seating positions. The term "rear outboard designated seating position" is defined in S4.2.4.1(b) as an "outboard designated seating position" located rearward of the front seat(s). If by the phrase "middle and rear outboard seating positions" you are referring to outboard seating positions in different rows of seats located behind the front seat(s), each such position that is forward-facing must be equipped with lap/shoulder belts after September 1, 1991. If instead the term "middle" is referring to center seating position(s) on bench seats, such positions may be equipped with either lap or lap/shoulder belts. Rearward-facing seats may also be equipped with either lap or lap/shoulder belts.
I hope this information is useful. If you have any further questions or need some additional information on this subject, please contact Mary Versailles of my staff at this address or by telephone at (202) 366-2992.
Sincerely,
Paul Jackson Rice Chief Counsel ref:208 D. 8/14/91