Interpretation ID: 86-2.3

TYPE: INTERPRETATION-NHTSA

DATE: 03/03/86

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: The Honorable Bobbi Fiedler

TITLE: FMVSS INTERPRETATION

TEXT:

The Honorable Bobbi Fiedler House of Representatives 1607 Longworth House Office Building Washington, D.C. 20515

Dear Ms. Fiedler:

Thank you for your letter enclosing correspondence from your constituent, Mr. William Griffiths of Newbury Park, who asked several questions about our regulations for safety belts on passenger motor vehicles, buses and school buses. Your letter has been referred to my office for reply.

Your constituent asked why safety belt designs vary between different seating positions and among different types of motor vehicles. He observes that some vehicles have a combination of pelvic and upper torso restraints ("lap and shoulder belts") in the front seats, while providing only lap belts for the rear seats. He further notes that safety belts are not required for passengers in buses and school buses. Apparently Mr. Griffiths believes that shoulder belts are uncomfortable and feels that they should not be installed in the front seats of passenger motor vehicles.

I am pleased to have this opportunity to clarify our requirements for your constituent. The National Highway Traffic Safety Administration (NHTSA) is responsible for developing safety standards for all new motor vehicles and items of motor vehicle equipment. Federal Motor Vehicle Safety Standard (FMVSS) No. 208, Occupant Crash Protection, establishes performance requirements for the protection of vehicle occupants in crashes. Under FMVSS No. 208, motor vehicle manufacturers must provide lap and shoulder belts for front outboard passenger positions in order to comply with the standard. Since persons in the front seating positions of an automobile should be protected from rigid structures forward of those positions, such as the windshield pillars, He believe that an upper torso restraint of some kind is necessary. Our requirements differ for the rear seating positions, where only a lap belt need be provided, because the area forward of those positions does not contain the relatively hard surfaces found in the areas surrounding the front seats.

As Mr. Griffiths has noted, our safety standards for buses and school buses do not require safety belts for passengers. NHTSA does not require safety belts for transit-type buses because the crash forces experienced by those vehicles are less severe than those of lighter vehicles in similar collisions. Also, the safety record for transit buses is good Accordingly, we believe that revising our requirements for their seating systems would not reduce injuries substantially. Safety belts are not required for passengers in large school buses because those vehicles are required to provide high levels of occupant crash protection through a concept called :"compartmentalization." Compartmentalization requires that the interior of large school buses by constructed so that children are protected without the need to use safety belts. The seating improvements include higher and stronger seat backs, additional seat padding, hand improved seat spacing and performance.

Your constituent might be interested to know that we have addressed his concern regarding the discomfort some passengers experience with safety belts equipped with shoulder restraints. We have taken steps to improve the comfort and convenience of safety belt Systems by a recent amendment to our safety standards. A copy of the amendment is enclosed.

I hope this information is helpful. Please do not hesitate to contact my office if you have further questions.

Sincerely,

Original Signed By

Erika Z. Jones Chief Counsel

Enclosure

Congress of the United States House of Representatives Washington D.C.

Dec. 20 1985

Nancy Miller Department of Transportation

Sir:

The attached communication is sent for your consideration. Please investigate the statements contained therein and forward me the necessary information for reply, returning the enclosed correspondence with your answer.

Yours truly,

M. C.

Please Return ATTN: Louise Gessford 1607 Longworth

Rep Fiedler

Why do the car manufacturers have different seat belt configurations, with the belt in the front seats going around the waist and over the shoulder and the back seat only around waist, some have front seat only around waist?

Why do the city buses not have seat belts for the passengers? Also school buses?

We the people are the testing area for the car industry.

These are a few of the negative views after talking to many people about new seat belt law.

Have they thought about people who have had heart surgery, and other people having surgery who still have very tender areas, also women with large breasts, the only relief is to ride with your hand under the belt in these irritating areas in order to obey the law. This seems quite stupid.

Summation: There definitely should be more research done on this problem: either have the car manufacturers install waist belts in all cars or resort to air bags.

Will await your reply

William Griffith 815 492-5432