Interpretation ID: aiam4086
House of Representatives
1607 Longworth House Office Building
Washington
D.C. 20515;
Dear Ms. Fiedler: Thank you for your letter enclosing corresponence (sic) from you constituent, Mr. William Griffiths of Newbury Park, who asked several questions about our regulations for safety belts on passenger motor vehicles, buses and school buses. Your letter has been referred to my office for reply.; Your constituent asked why safety belt designs vary between differen seating positions and among different types of motor vehicles. He observes that some vehicles have a combination of pelvic and upper torso restraints ('lap and shoulder belts') in the front seats, while providing only lap belts for the rear seats. He further notes that safety belts are not required for passengers in buses and school buses. Apparently Mr. Griffiths believes that shoulder belts are uncomfortable and feels that they should not be installed in the front seats of passenger motor vehicles.; I am pleased to have this opportunity to clarify our requirements fo your constituent. The National Highway Traffic Safety Administration (NHTSA) is responsible for developing safety standards for all new motor vehicles and items of motor vehicle equipment. Federal Motor Vehicle Safety Standard (FMVSS) No. 208, *Occupant Crash Protection*, establishes performance requirements for the protection of vehicle occupants in crashes. Under FMVSS No. 208, motor vehicle manufacturers must provide lap and shoulder belts for front outboard passenger positions in order to comply with the standard. Since persons in the front seating positions of an automobile should be protected from rigid structures forward of those positions, such as the windshield pillars, we believe that an upper torso restraint of some kind is necessary. Our requirements differ for the rear seating positions, where only a lap belt need be provided, because the area forward of those positions does not contain the relatively hard surfaces found in the areas surrounding the front seats.; As Mr. Griffiths has noted, our safety standards for buses and schoo buses do not require safety belts for passengers. NHTSA does not require safety belts for transit-type buses because the crash forces experienced by those vehicles are less severe than those of lighter vehicles in similar collisions. Also, the safety record for transit buses is good. Accordingly, we believe that revising our requirements for their seating systems would not reduce injuries substantially. Safety belts are not required for passengers in large school buses because those vehicles are required to provide high levels of occupant crash protection through a concept called 'compartmentalization.' Compartmentalization requires that the interior of large school buses be constructed so that children are protected without the need to use safety belts. The seating improvements include higher and stronger seat backs, additional seat padding, and improved seat spacing and performance.; Your constituent might be interested to know that we have addressed hi concern regarding the discomfort some passengers experience with safety belts equipped with shoulder restraints. We have taken steps to improve the comfort and convenience of safety belt systems by a recent amendment to our safety standards. A copy of the amendment is enclosed.; I hope this information is helpful. Please do not hesitate to contac my office if you have further questions.; Sincerely, Erika Z. Jones, Chief Counsel