Interpretation ID: 1984-3.7

TYPE: INTERPRETATION-NHTSA

DATE: 08/17/84

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Gerald D. Peltzer

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your letter of July 18, 1984, requesting information on what safety regulations apply to a "sleeper-passenger carrier" that you manufacture. The following discussion explains the regulations applicable to your product.

Since your product is sold as an accessory or addition to a motor vehicle, the National Highway Traffic Safety Administration considers it to be an item of motor vehicle equipment. The agency has issued several Federal motor vehicle safety standards applicable to your product. Standard No. 126, Truck-Camper Loading, requires camper manufacturers to provide certain certification, identification and loading information on a label affixed to their product. The standard defines "camper" as "a structure designed to be mounted in the cargo area of a truck, or attached to an incomplete vehicle with motive power, for the purpose of providing shelter for persons." Since your product is designed to be mounted in the cargo area of a pickup truck and provides shelter for its occupants, it would be considered a camper and thus must comply with Standard No. 126.

You indicate in your letter that your product contains windows with "safety glass." Standard No. 205, Glazing Materials, sets requirements for glazing used in motor vehicles, including campers. Standard No. 205 incorporates by reference the American National Standard "Safety Code for Safety Glazing Materials for Glazing Motor Vehicles Operating on Land Highway," Z26.1-1977, January 26, 1977, as supplemented by Z26.1a, July 3, 1980 (ANS-Z26). The standard established both performance and labelling requirements for the glazing used in your camper.

You state that your product has a bench seat across the back and a cushion across the front. Since you describe your product as in part a "passenger carrier," it is likely that the seat and the cushion will be used as a seating position while the vehicle is in motion and thus would be considered a designated seating position by the agency. If your product is installed as an item of original equipment on a truck before its sale to its first purchaser, the designated seating positions must conform to the requirements of Standard No. 207, Seating Systems; Standard No. 208, Occupant Crash Protection; Standard No. 209, Seat Belt Assemblies and Standard NO. 210, Seat Belt Assembly Anchorages. I have enclosed an information sheet explaining how you can obtain copies of our safety standards.

If your product is sold as an item of aftermarket equipment to be installed by a vehicle owner, it would not be required to comply with Standards Nos. 207, 208, 209, and 210. However, we strongly recommend you do provide seat belts properly anchored at each seating position.

You are also required to comply with Part 566, Manufacturer Identification, a copy of which is enclosed. That regulation requires you to submit certain identifying information and a description of the product you produce.

Finally, as a manufacturer of an item of motor vehicle equipment, you have a responsibility under section 151 et seq. of the National Traffic and Motor Vehicle Safety Act to conduct a notification and remedy campaign if you or the agency determines that your product contains a safety-related defect or does not comply with an applicable standard. A copy of the Act is enclosed.

If you have any further questions, please let me know. ENCLS.

July 18, 1984

Peltzer Manufacturing

National Highway Traffic Safety Administration

Attention: Chief Council

Dear Sirs:

I am writing in regard to the safety regulations that apply to the manufacture of a sleeper-passenger carrier that mounts in the front 40" inches of a pickup box. The main outside structure is fiberglass approximately three-sixteenths of an inch thick, completely carpeted inside. It has a bench seat across the back with a backrest on each side of the door and a cushion across the front that can be folded down to make a sleeper bunk.

The unit has a 15" x 54" bi-parting safety glass in front to match the rear window of the truck cab. The side windows are 22" X 30" safety glass slider windows with screens. The front of the unit is bolted into brackets that are bolted into the front stake pockets of the truck box. The rear of the unit has 1 1/2" x 3/16" "L" shaped metal brackets that are bolted to the sleeper-passenger carrier and go under the upper ledge of the pickup box. The 22" x 36" x 1 3/8" door in the rear of the unit is mounted in an aluminum frame. I am using a Bargman L-300 motor home lock.

Enclosed find a picture and a diagram of the unit. Please send me information on how to get this unit safety approved.

Gerald D. Peltzer

(Graphics omitted)

(Graphics omitted)