Interpretation ID: nht79-3.39

DATE: 12/27/79

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Professional Automotive Consultant

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your recent letter asking about the applicable Federal requirements for seat belts in a pickup truck that has been modified to be a convertible by removal of the top. Specifically, you ask what should be done with the shoulder portions of the seat belt assemblies in these vehicles.

I am enclosing for your information a past agency interpretation concerning this same question. You will note that the modified pickup must be in compliance with the Federal safety standards that would have been applicable to a convertible truck at the time the pickup was originally manufactured. Since Safety Standard No. 208, Occupant Crash Protection, permits convertible trucks to be equipped with either Type 1 belts (lap belts) or Type 2 belts (lap and shoulder combination belts) at front outboard designated seating positions, the modified pickup would only be required to have a lap belt. Of course, your client is certainly permitted to retain the lap and shoulder belt if he chooses. We cannot, however, recommend how the shoulder portion of the belt assembly should be attached to the modified vehicle.

Sincerely,

ATTACH.

November 7, 1979

Francis Armstrong, Director -- Office of Vehicle Compliance Enforcement, National Highway Traffic Administration, U.S. Dept. of Transportation

Dear Mr. Armstrong:

I am currently working with a client who is involved with a "Conversion" whereby the top of a pickup truck cab is cut behind the windshield and slightly above the rear bed height. After cutting this top off of the cab, it is fitted with moulded gaskets and held by four (4) aircraft quality latches to produce a convertible truck.

My questions are not concerned with the above process. I am now concerned about the shoulder harness and where it should be located. Naturally the harness becomes inoperable when the top is removed since the factory harnesses are pivoted in the top.

I would think that under the circumstances this finished vehicle should be treated as any other "convertible" with respect to seat belts and harnesses.

Please enlighten me as to what you suggest I should advise my client to do with respect to the relocation or elimination of the detachable upper torso portion of the seat belt assembly.

I thank you very much for your interest in this matter and look forward to your prompt reply.

Sincerely,

Don Johnson -- PROFESSIONAL AUTOMOTIVE CONSULTANT