Interpretation ID: nht89-3.45

TYPE: INTERPRETATION-NHTSA

DATE: 11/27/89

FROM: SCOTT K. HILLER -- CE WHITE COMPANY

TO: NHTSA

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 01/12/90 FROM STEPHEN P. WOOD -- NHTSA TO SCOTT K. HILLER -- CE WHITE COMPANY; REDBOOK A35; STANDARD 210

TEXT: Dear N.H.T.S.A.:

I request a written, legal interpretation of the Federal Motor Vehicle Safety Standard No. 210 with regard to test procedures involving multi-passenger, passenger seats for school buses under 10,000 GVWR.

The situation is as follows:

1. The seat belts are mounted to the frame itself via a 1 1/4" angle bar running the width of the seat. (See photographs)

2. Each seating position has an individual set of seat belt mounting holes punched into the angle iron bar. (See photographs)

My question is does each seating position, when tested per @ 5.1 of FMVSS 210, have to be pulled simultaneously or should they be pulled individually?

I will be looking forward to your letter. Thank you for your help in this matter.

Sincerely,

ENCLOSURES

(Photo Omitted)

Two passenger school bus passenger seat frame with seat belts attached. Front View.

(Photo Omitted)

Back view of a two passenger school bus seat with frame attached seat belts.

(Photo Omitted)

Top view of a 2 passenger school bus seat with seat belt bar mounted on seat frame for frame mounted seat belts. Note two separate sets of holes.

(Photo Omitted) Front view of a two passenger school bus seat with seat belts attached to seat frame.

(Photo Omitted)

Top forward view of a two passenger school bus seat frame which illustrates the seat belt attachment bar as frame mounted.