Interpretation ID: nht93-6.43

DATE: September 21, 1993

FROM: Joe Takacs -- Director of Engineering, Kinedyne Corporation

TO: Office of Chief Counsel -- NHTSA

TITLE: Ref: Final rule amending Standard No. 222 School Bus Passenger Seating and Crash Protection FMVSS; Federal Register/Vol. 58, No. 170/Friday/ September 3, 1993/Rules and Regulations; Docket No. 90-05; Notice 5; 49 CFR Part 571

TEXT:

Based on the above referenced document that denied Kinedyne Corporation's petition but clarified the intent of implementing FMVSS 209 requirements for wheelchair securement systems, we would appreciate your comments on our interpretation of the final rule:

1. The webbing used in Kinedyne Corporation's wheelchair strap assemblies is industrial type 1.00 inch or 2.00 inch wide polyester webbing that meet the strength and other requirements of S4.2 of FMVSS No. 209. Therefore, this webbing is acceptable for use on wheelchair securement systems per FMVSS No.222.

2. The hardware used on Kinedyne Corporation's wheelchair strap assemblies are industrial type 1.00 inch or 2.00 inch overcenter, ratchet or cam buckles; wire hooks; snap hooks and track fittings which meet the strength and other requirements, as specified, in S4.3 of FMVSS No. 209. Therefore, these fittings are acceptable for use on wheelchair securement systems per FMVSS No. 222.

Industrial type webbing and hardware used in our wheelchair securement strap assemblies have been successfully used in wheelchair securement applications for approximately 20 years. We trust that these same assemblies meet the requirements of Amended FMVSS No. 222.

We would appreciate a reply within the next 30 days. Thank you for your assistance.