Interpretation ID: aiam1677
Field Enterprises Education Corp.
Merchandise Mart Plaza
Chicago
Illinois 60654;
Dear Mr. Winiarski: Your letter of October 8, 1974, to Mr. Bobby Boaz has been forwarded t this office for reply. You appear to be interested in obtaining some general statements regarding the applicability of motor vehicle safety standards to different types of motor vehicles.; We attempt to apply each Federal motor vehicle safety standard to a wide range of motor vehicles and motor vehicle equipment as is reasonable, practicable and appropriate. It is not entirely accurate, however, to say that the standards apply to the performance of equipment which vehicles are required to have. The standards are divided conceptually into three types: those which apply to new vehicles, those which apply to motor vehicle equipment (*e.g.* tires, child seats, etc.) and those which apply to both vehicles and equipment. In case of a standard which applies to vehicles, the tests employed by the standard can take into account vehicle structure, weight, and design. In other words it is the method by which equipment is integrated into a vehicle that is important, rather than the performance of equipment taken alone.; Standards which apply to vehicles specify the particular vehicle type to which they apply. Most early vehicle standards applied only to passenger cars. Since that time we have attempted to expand the applicability of some of these standards to other vehicle types. In each case, as I indicated above, a standard must be reasonable, practicable, and appropriate for the type of vehicle to which it is applied. In some cases, this is a matter of technology as you suggest. In other, however, the question may be one of safety need. For example, some standards do not apply to trailers (*e.g.*, Standard No. 302, 'Flammability of interior materials') or to equipment for use in trailers (No. 205. 'Glazing materials') because State laws prohibit people from riding in trailers. In this regard standards can also be directed at particular vehicle types to alleviate safety problems particular to them. A good example of this is Standard No. 217, 'Bus window retention and release.'; Your statements regarding seat belts and the applicability of Standard No. 208,209, and 210 are not correct. While these requirements are somewhat complex, I believe an appropriate summary would be that seat belts and anchorages are required at all permanent seating positions including lateral or rearward positions, in all motor vehicles except trailers, motorcycles, and the passenger seats in buses.; Yours truly, Richard B. Dyson, Acting Chief Counsel