Interpretation ID: nht93-6.20

DATE: August 18, 1993

FROM: Jack McIntyre -- V.Pres., Tie Tech Inc.

TO: John Womack -- Office of Chief Counsel, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 11/23/93 from John Womack to Jack McIntyre (A41; Std. 209; Std. 222) and letter dated 9/15/93 from Jack McIntyre to John Womack (OCC-9123)

TEXT:

In January 1993, the National Highway Traffic Safety Administration issued requirements for wheelchair securement systems that are used on school buses. These requirements are included in Federal Motor Vehicle Safety Standard 222. As stated in the comments that were provided to the Proposed Rule, these standards are needed.

In reviewing the final requirements, however, it appears that a particular requirement for the wheelchair securement system was adopted that is inconsistent with the securement systems being manufactured by most wheelchair securement manufacturers. Also, this requirement does not appear to be directly relevant to the crash performance of a wheelchair securement belt. The specific requirement I am referring to appears in S5.4.2, which references the requirements of Type 1 safety belts of FMVSS 209, and requires that the belt webbing be not less than 1.8 inches wide.

There is no apparent need to specify a minimum belt width for wheelchair securement belts as there is for occupant restraint belts. I understand that the belt width requirements for occupant restraint systems is to spread the crash forces over a larger area of the body. There is no such need for securement belts. Currently the industry standard for securement belts is a 1 inch wide belt made from polyester that easily meets the 6,000 pound force requirements of FMVSS 209 and 222. Additionally, the 1 inch wide belts made from polyester have less stretch than the 1.8 inch nylon belts.

Finally, it is noted that 1 inch wide securement belts and related hardware are easier and less cumbersome to connect to a wheelchair, particularly in the tight circumstances that exist on school buses in many instances, than are the 1.8 inch wide belts and their larger pieces of hardware.

Based on the above, I petition to change the requirement that the wheelchair securement belt must be at least 1.8 inches wide. The cost to the wheelchair securement industry to retool for the wider belts would be significant, without any added benefits in terms of safety to occupants of wheelchairs in school buses.

Thank you for your consideration.