Interpretation ID: 2395y
Senior Sales Engineer
Transportation Manufacturing Corp.
Box 5670 (R.I.A.C.)
Roswell, NM 88202-5070
Dear Mr. Schreyer:
This responds to your letter to Mr. Harry Thompson of this agency's Office of Vehicle Safety Compliance, seeking an interpretation of Standard No. 210, Seat Belt Assembly Anchorages (49 CFR 571.210). You posed two questions, which I will answer in the order presented.
First, you noted that the State of Nevada will be procuring some prison buses, equipped with lap-only safety belts at the passenger seating positions. You correctly noted that no safety standard requires safety belts to be installed for passenger seating positions on buses, but asked if this agency could "provide direction on what course of action [TMC] should take." You asked particularly whether you should design the anchorages for the lap-only safety belts to conform with the requirements of Standard No. 210.
NHTSA answered this question in a March 22, 1989 letter to Mr. Keith McDowell, a copy of which is enclosed for your information. As we said in that letter, NHTSA must decline to issue any "guidelines" beyond or in addition to the requirements set forth in the safety standards. Therefore, since Standard No. 210 expressly exempts passenger seats in buses from the standard's anchorage requirements, Federal law leaves the question of how any such anchorages should be designed entirely up to the judgment of the bus manufacturer. Please note, however, that the State of Nevada is free to specify certain design and performance criteria with which these anchorages must comply in its contract for these buses.
Second, you asked for a clarification of the testing conducted to determine compliance with Standard No. 210. Section S4.2 of Standard No. 210 sets forth the strength test with which anchorages must comply. Section S4.2.4 of Standard No. 210 reads as follows: "Except for common seat belt anchorages for forward-facing and rearward-facing seats, floor-mounted seat belt anchorages for adjacent designated seating positions shall be tested by simultaneously loading the seat belt assemblies attached to those anchorages." You asked whether all seats in the coach must be tested simultaneously or whether a single seat would be tested, and then the next seat tested, and so forth.
Please note that the only anchorages subject to a simultaneous testing requirement are "floor-mounted" anchorages for "adjacent designated seating positions." Assuming that there is an aisle or some other separation between the seat assemblies in your buses, the only "adjacent" designated seating positions would be those common to one occupant seat. Therefore, no more than one occupant seat's anchorages would be tested simultaneously under Standard No. 210. Even those anchorages common to one occupant seat would be tested simultaneously only if the anchorages were floor-mounted.
Sincerely,
Stephen P. Wood Acting Chief Counsel
Enclosure
/ref:210 d:4/9/90