Interpretation ID: aiam1878
Jr.
Brougham Industries
P.O. Box 768
101 Bolivar Street
Sanger
TX 76266;
Dear Mr. Knaur: This responds to your March 17, 1975, request for an explanation of th seat belt assembly installation requirements of Standard No. 208, *Occupant crash protection*, as they apply to motor homes with a gross vehicle weight rating (GVWR) of more than 10,000 pounds, and those with a GVWR of 10,000 pounds or less.; The standard requires that motor homes with a GVWR of more than 10,00 pounds be equipped with 'passive' crash protection of a certain level (S4.3.1) or a Type 1 or Type 2 seat belt assembly at each designated seating position (S4.3.2).; Motor homes with a GVWR of 10,000 pounds or less must be equipped wit 'passive' crash protection of a certain level (S4.2.1.1) or a Type 2 seat belt assembly at each outboard designated seating position that includes the windshield header within the head impact area, and a Type 1 or Type 2 seat belt assembly at each other designated seating position(S4.2.1.2).; At the front outboard designated seating position, you state that th incomplete vehicle manufacturer provides Type 1 seat belts. Unless the documentation, provided under Part 568 of our regulations (49 CFR Part 568), states that modification of the Type 1 seat belts is required to meet Standard No. 208, it appears that the vehicle windshield header is not within the head impact area and that Type 1 seat belts meet the requirement.; You point out that some manufacturers may not provide as man designated seating positions as there are sleeping accommodations in the vehicle. We evaluated the proportion of this problem recently because of the possibility that occupants were not being provided with enough Type 1 seat belts. An informal but comprehensive survey at a recent trade show indicated that the problem is extremely limited. If you have information that this practice is becoming more common, please provide this office with more specific identification of manufacturer and model line.; We do appreciate your efforts to provide your purchasers with a hig level of crash protection.; Sincerely, James C. Schultz, Chief Counsel