Interpretation ID: aiam3173
Professional Automotive Consultant
25406 Malibu Road
Malibu
CA 90265;
Dear Mr. Johnson: This responds to your recent letter asking about the applicable Federa requirements for seat belts in a pickup truck that has been modified to be a convertible by removal of the top. Specifically, you ask what should be done with the shoulder portions of the seat belt assemblies in these vehicles.; I am enclosing for your information a past agency interpretatio concerning this same question. You will note that the modified pickup must be in compliance with the Federal safety standards that would have been applicable to a convertible truck at the time the pickup was originally manufactured. Since Safety Standard No. 208, *Occupant Crash Protection*, permits convertible trucks to be equipped with either Type 1 belts (lap belts) or Type 2 belts (lap and shoulder combination belts) at front outboard designated seating positions, the modified pickup would only be required to have a lap belt. Of course, your client is certainly permitted to retain the lap and shoulder belt if he chooses. We cannot, however, recommend how the shoulder portion of the belt assembly should be attached to the modified vehicle.; Sincerely, Frank Berndt, Chief Counsel