Interpretation ID: 77-4.34

TYPE: INTERPRETATION-NHTSA

DATE: 11/10/77

FROM: AUTHOR UNAVAILABLE; J. J. Levin, Jr.; NHTSA

TO: Indiana Mills and Manufacturing, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of October 4, 1977, to Mr. Francis Armstrong of our Office of Standards Enforcement, in which you asked whether our regulations require seat belts in fifth wheel vehicles.

Our seat belt requirements are specified in Federal Motor Vehicle Safety Standard No. 208 (49 CFR 571.208), which applies to passenger cars, multipurpose passenger vehicles, trucks and buses. I am assuming that by fifth wheel vehicle you mean a towed vehicle attached to the towing vehicle by means of a fifth wheel. If I am correct in this assumption, these vehicles would be classified as trailers, which are not subject to Standard No. 208. There would therefore be no Federal requirement for seat belts in these vehicles.

SINCERELY,

October 4, 1977

Francis Armstrong, Director Office of Standards Enforcements Motor Vehicle Programs National Highway Traffic Safety Administration

To further promote the R.V. industry, the Pennsylvania Recreational Vehicle and Camping Association (PRVCA) supported fifth-wheel riding, provided certain safety features were incorported.

Now, fifth wheel riding has been made part of the Pennsylvania Vehicle code, becoming legal July 1, 1977. This brings to 25 the number of states that have made it legal to ride in fifth wheels. The law requires seat belts in all designated seating. Would you please advise me as to how the code speaks to the use of seat belts in fifth wheel vehicles.

Thank you for your assistance.

Robert W. Locke Manager RV Sales -- INDIANA MILLS AND MANUFACTURING, INC.