Interpretation ID: aiam2170
Chief
Standards and Specifications Division
Bureau of Standards
Department of General Services
2221 Forster Street
Harrisburg
PA 17125;
Dear Mr. Erne: This responds to your December 12, 1975, question whether Motor Vehicl Safety Standard No. 207, *Seating Systems*, requires a restraining device for side-facing folding seats that are to (sic) used in buses and van-type vehicles.; Subsection S4.3 of Safety Standard No. 207 requires that side-facin folding seats be equipped with a restraining device, unless the seat is a 'passenger seat in a bus or a seat having a back that is adjustable only for the comfort of its occupant.'; A 'bus' is defined by Section 571.3 as a 'motor vehicle with motiv power, except a trailer, designed for carrying more than 10 persons.' Therefore, in order to come within the 'bus' exception of S4.3, the vehicle must be designed for carrying more than 10 persons. Otherwise a restraining device is required.; A 'van-type' vehicle is either a 'bus', a 'multi-purpose passenge vehicle,' or a 'truck,' depending on the number of designated seating positions. If the vehicle is designed for 10 persons or less, it is a multi-purpose passenger vehicle, not a bus, and S4.3 requires a restraining device for side-facing folding seats.; Please contact us if we can be of any further assistance. Yours truly, Richard B. Dyson, Assistant Chief Counsel