Interpretation ID: aiam0374
Washington Representative
Trailer Coach Association
1800 North Kent Street
Suite 922
Arlington
VA 22209;
Dear Mr. Moss: This is in reply to your letter of June 7, requesting interpretation of Standard No. 207, Seating Systems, and Standard No. 208, Occupant Crash Protection.; First, with respect to Standard No. 207, you have asked whethe designated seating positions must be labeled as such. Our response is that the labeling section requires labels on seats not designated for occupancy while the vehicle is in motion but does not require designated seating positions to be labeled.; With respect to the nature and content of the label on a seat no designated for occupancy, the standard states that the seat must be 'conspicuously labeled to that effect.' There are thus two general requirements: that the label be conspicuous and that it indicate that the seat is not to be occupied while the vehicle is in motion. The requirement for conspicuousness relates to the location of the label and the prominence of its lettering. Generally speaking, it would have to be located so that it could be seen by a person preparing to occupy the seat and of a size that could be read by the occupant in the normal motion of sitting. The statement on the label must clearly indicate that the seat is not to be occupied while the vehicle is in motion, but the exact wording is left to the manufacturer.; Standard No. 208 requires that MPV's and trucks with a GVWR of les than 10,000 pounds, manufactured from January 1, 1972 to August 15, 1975, must elect either a passive protection system or a seat belt system that requires Type 2 seat belt assemblies at outboard designated seating positions that include the windshield header within the head impact area. A similar requirement, without the passive option, goes into effect July 1, 1971, for these vehicles. Your question is whether, if a seating position does not have the windshield header within the head impact area, it is permitted to have a Type 1 seat belt assembly. Our response is that the standard permits a Type 1 belt for such a position.; Please advise us if we can be of further assistance. Sincerely, Lawrence R. Schneider, Acting Chief Counsel