Interpretation ID: aiam3065
Webster & Chamberlain
1747 Pennsylvania Avenue
N.W.
Washington
DC 20006;
Dear Mr. Chamberlain: This responds to your letter of August 2, 1979, concerning th requirements of Safety Standard No. 208, *Occupant Crash Protection*, as applicable to vehicles sold to the U.S. Postal Service.; Under the general requirements of paragraph S4.2.2 for trucks an multipurpose passenger vehicles with GVWR's of 10,000 pound or less, Type II seat belt assemblies are required for outboard designated seating positions. That paragraph does provide optional requirements, however, for certain vehicles that are designed to be exclusively sold to the U.S. Postal Service. Under the optional requirements, these vehicles can instead meet the requirements of S4.2.1.2 which allow the use of Type I seat belts at outboard designated seating positions in convertibles, open-body type vehicles, walk-in van- type vehicles and for outboard seating positions that do not include the windshield header in the head impact area. Therefore, if the 'X-1' vehicles described in your letter are any of these vehicle types and are sold exclusively to the Postal Service, they may legally be equipped with either Type I or Type II assemblies, at the manufacturer's option.; Regarding your second question, whether or not the 'X-1' vehicle conform to Postal Service specifications is a matter of contractual agreement that must be determined by the contracting parties. The most the agency can say is that the 'X-1' vehicles would be in compliance with Safety Standard No. 208 if they qualify as one of the vehicle types discussed above.; I hope this has been responsive to your inquiry. Sincerely, Frank Berndt, Chief Counsel