Interpretation ID: aiam4317
Health Policy and Planning Consultant
ECRI
5200 Butler Pike
Plymouth Meeting
PA 19462;
Dear Ms. Stevens: Thank you for your letter of March 26, 1987, asking several question about how our regulations on safety belts would apply to side and rear-facing seats in emergency medical vehicles. I hope the following discussion answers your questions.; You explained in your letter that most emergency medical vehicles hav a rear-facing seat that is typically located behind the driver's seat. The photographs you sent with your letter show that in one of the two vehicle designs you photographed, the rear-facing seat appears to be a typical vehicle seat, referred to as a 'captain's chair,' often used in a van-type vehicle. In the other emergency vehicle design show in your photographs, there is a rearward-facing, bench-type seat with a padded seat pan and back installed directly behind the driver.; You further explained that, depending on the number of stretchers th vehicle is designed to carry, there may be another seating area in the vehicle. In single-stretcher vehicles, there is a squad bench, which your photographs show is a set of storage compartments with a padded top, located next to the stretcher. You explained that emergency personnel may sit on the squad bench to attend the the(sic) patient while the vehicle is in motion. You further explained that personnel in dual-stretcher vehicles sit on the empty stretcher to attend to the patient. You said that use of a safety belt in those positions is too restrictive to allow emergency personnel to provide acute care to patients during transports.; Standard No. 208, *Occupant Crash Protection*, sets requirements fo the installation of occupant restraints in motor vehicles. The emergency medical vehicles shown in your photographs would be classified as multipurpose passenger vehicles under our regulations since they are designed to carry 10 or fewer persons and are built on a truck chassis. Standard No. 208 requires manufacturer of new multipurpose passenger vehicles to install a safety belt for each designated seating position. Part 571.3 of our regulations defines, impart, a designated seating position as:; >>>any plan view location capable of accommodating a person at least a large as 5th percentile female, if the overall seat configuration and design and vehicle design is likely to be used as a seating position while the vehicle is in motion, except for auxiliary seating accommodations such as temporary or folding jump seats.<<<; The agency considers the two types of rearward-facing seats in th emergency medical vehicles you photographed to be designated seating positions. Those seats are designed and built in the same manner as conventional vehicle seats in that they have a padded seat pan and a high padded seat back. In fact, the one seat appears to be a conventional 'captain's chair' which has been mounted in a rearward-facing position. The two rearward-facing seats are also designed to be used on a routine basis by an emergency medical personnel as the vehicle travels to its destination.; In contrast, the agency does not consider as squad bench or a stretche to be a designed or built in the same manner as a conventional vehicle seat. Although they have the equivalent of a seat pan, they do not have a seat back. Most importantly, both the squad bench and stretcher are meant to be used on a temporary basis as auxiliary seating position by emergency medical personnel as they provide treatment to a patient. Thus, as an auxiliary seating area, they would not be considered a designated seating position and therefore not subject to the safety belt installation requirement of Standard No. 208.; If you have any further questions, please let me know. Sincerely, Erika Z. Jones, Chief Counsel