Interpretation ID: aiam3590
President
Kamlot Marketing Inc.
4311 East 104th Street
Tulsa
OK 74136;
Dear Mr. Braden: This responds to your recent letter requesting information concernin the type of seat belts which must be used in the driver and passenger seats of a Ford van F150. Your company is apparently converting these vehicles by adding 'plush' seats and a rear sofa.; Paragraph S4.2.2 of Safety Standard No. 208, *Occupant Cras Protection*, (49 CFR Part 571) specifies that trucks with a GVWR of 10,000 pounds or less shall meet the same requirements of the standard that are specified for passenger cars. This would include the Ford van to which you refer. Paragraph S4.1.2.3 of the standard specifies that passenger cars must be equipped with a Type 2 seat belt assembly (non-detachable lap and shoulder belt) at each front outboard designated seating position. At all other seating positions, either a Type 1 belt assembly (lap belt only) or a Type 2 assembly must be used. Therefore, the vans that you are converting must have Type 2 belts in the two front seating positions and must have either Type 2 or Type 1 belts in the rear seating positions. The only exception to this requirement is that a forward control van manufactured prior to September 1, 1981, was permitted to have either Type 1 or Type 2 belts in front outboard seating positions. I gather from your letter that the vans you are converting were manufactured after that date and would not qualify under this exception.; You should also note that the sofa you are installing in the rear o the van would likely qualify as having three designated seating positions and would have to have three sets of seat belts (Type 1/lap belts). I assume the sofa has three seating positions since your letter states the van is a 7-passenger vehicle.; Please contact Hugh Oates of my staff if you have any furthe questions.; Sincerely, Frank Berndt, Chief Counsel