Interpretation ID: aiam3809
P.E.
Talbott Associates Inc.
& S.E. 97th Avenue
Portland
OR 97216-2498;
Dear Mr. Day: This responds to your letter to this office asking for a interpretation of Federal Motor Vehicle Safety Standard No. 208, *Occupant Crash Protection* (49 CFR S571.208). Specifically, you asked if Standard No. 208 requires that all bus passengers be restrained from ejection in the event of a rollover which is severe enough to destroy the integrity of the passenger compartment. Standard No. 208 specifies that the designated seating position for the driver must offer full automatic protection for the occupant in those circumstances *or* that the seating position must be equipped with a seat belt assembly that conforms to the requirements of Standard No. 209, *Seat Belt Assemblies*. No requirements are specified for the other designated seating positions on the bus.; Section S4.4 of Standard No. 208 specifies the protection which buse must afford the occupants, and allows the bus to comply with one of two protection requirements. The first option, set forth in section S4.4.1, is for the vehicle to meet the crash protection requirements set forth in section S5 of the standard (which include restraining the occupant from ejection in the event of a rollover) by means that require no action by the vehicle occupant. This requirement, however, must be met only with respect to an anthropomorphic test device in the driver's designated seating position. The second option, as specified in section S4.4.2, is for the vehicle to be equipped with either a Type 1 or Type 2 seat belt assembly that conforms to Standard No. 209. Again, this option applies only to the driver's designated seating position. Neither of these options sets forth any requirements applicable to any other designated seating position in the bus.; Please feel free to contact me should you have any further questions o need more information on this subject.; Sincerely, Frank Berndt, Chief Counsel