Interpretation ID: nht72-3.28

DATE: 06/15/72

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Wayne Transportation Division

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of June 1, 1972, in which you asked whether a bus passenger seat to which you plan to attach seat belts would be required to conform to Motor Vehicle Safety Standard No. 207, Seating Systems, and No. 210, Seat Belt Anchorages.

The seat would not be required to conform to either standard. Each expressly exempts bus passenger seats from compliance with its requirements. It is our opinion that if a manufacturer provides a safety device which the applicable standards do not require him to provide, he is not bound to conform to the performance requirements of those standards.

Even though no standard is presently applicable, the agency is considering rulemaking action that will establish a standard for bus seating and we strongly urge you to provide the safest possible installation.