Interpretation ID: aiam3784
Assistant General Counsel
Grumman Corporation
445 Broad Hollow Road
Melville
NY 11747;
Dear Mr. Sweeney: This responds to your letter of November 22, 1983, regarding th application of Safety Standard No. 208 (49 CFR 571.208) to the new Kubvan minivan you intend to manufacture and distribute. You state in your letter that the Kubvan is a minivan designed primarily for delivery and utility service. You ask whether the Kubvan must be equipped with a lap and shoulder belt protection under S4.2.2.2 of the standard.; You state that Grumman Olson has built both left hand and right han drive models of the Kubvan. The right hand drive models are intended for use by the United States Postal Service (USPS). You add that Grumman Olson also plans to sell right hand vehicles to any and all interested customers.; Section 4.2.2.2 requires trucks with a GVWR of 10,000 pounds or less t provide a lap and shoulder belt protection system, except for those 'vehicles designed to be exclusively sold to the United States Postal Service.' As correctly stated in your letter, all Kubvans sold to customers other than the USPS must be equipped with a lap and shoulder belt assembly. However, based on the intent of S4.2.2.2 and the unique operating needs of the USPS, right hand Kubvans sold to the USPS need only be equipped with a lap belt system.; Sincerely, Frank Berndt, Chief Counsel