Interpretation ID: nht75-4.28
DATE: 07/30/75
FROM: Z. TAYLOR VINSON FOR RICHARD B. DYSON -- NHTSA
TO: Truck Body and Equipment Association, Inc.
TITLE: FMVSS INTERPRETATION
TEXT: This is in response to your letter of July 3, 1975, forwarding a copy of an earlier letter that evidently was never received by us. You asked whether a garbage truck that contained an auxiliary driver's position on the right side of the vehicle, with a separate set of controls, needs to have a seat at the auxiliary position, and whether access to such controls as the heater, wipers, and lights from this position is required.
We consider the standards relating to the driver's position as relating to the normal position, and not to an auxiliary driving position. The answer is no, therefore, to both of the above questions.
Yours Truly,
TRUCK BODY AND EQUIPMENT ASSOCIATION, INC.
July 3, 1975
Richard Dyson, Assistant Chief Counsel NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION
Enclosed please find a copy of a letter submitted to the NHTSA Office of Chief Counsel on May 19, 1975. In addition to the original cover letter, there were sales documents, a vehicle performance analysis, and several other pieces of background information.
We are still waiting to receive an interpretation on the vehicle in question.
If I can be of any help in expediting this matter please feel free to contact me.
Byron A. Crampton Manager of Engineering Services
TRUCK BODY AND EQUIPMENT ASSOCIATION INC.
May 19, 1975
James Schulz Chief Counsel NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION
Recently a member of TBEA's Refuse Body Division raised several questions concerning the applicability of certain Federal Motor Vehicle Safety Standards to a specific vocational vehicle.
The vehicle in question is a relatively new concept in a solid waste removal vehicle (Garbage Truck) designed for optimum manpower utilization. From the enclosed sales literature the basic operating configuration is apparent - a one man operation. The projected cost savings associated with this design are achieved by the reduction in the number of people required to operate these vehicles during the collection cycle. Aside from the cost savings benefits appreciated through this side loading type of collection vehicle, additional benefits are achieved in the area of operating safety. The one man side loading unit has been proven to be substantially safer to operate than the conventional rear loading unit.
The vehicle's construction is as unique as its operation. The conventional truck cab is partitioned off into two separate areas. The left hand section, equipped with (1) designated seating position, is conventionally controlled to allow for normal road operation to and from landfill areas. The right hand section of the cab is altered by removing the door, lowering the floor and installing an additional set of hand operated driver controls. This modified section then becomes a convenient stand-up curbside work station. The 500 to 600 stops per day require constant movement in and out of the vehicle and this curbside/curb level operating position allows the driver to easily move and load the collection vehicle. As stated earlier, there is no door, door hardware, or seating system located at the curbside control position.
With these facts in mind, are we correct in assuming that no seating system and corresponding hardware is required for this auxillary control position? In addition, is control accessibility required (i.e. heater, wipers, lights) for this auxillary control position?
Should any clarification be required, please feel free to contact me.
Byron A. Crampton Manager of Engineering Services