Interpretation ID: 9123
Vice President
Tie Tech Inc.
Post Office Box 5226
Lynnwood, WA 98046-5226
Dear Mr. McIntyre:
This responds to your letter in which you withdrew your petition for rulemaking of August 18, 1993, and requested an agency interpretation instead.
You referred to the final rule issued by this agency on January 15, 1993 (58 FR 4585), which amended Federal Motor Vehicle Safety Standard (FMVSS) 222. Specifically, paragraph S5.4.2.(a)(1) of the amendment provides that wheelchair securement devices composed of webbing or straps must meet the requirements for Type I safety belt systems specified in S4.2, among others, of FMVSS 209. You stated that there is no need to specify a minimum width for wheelchair securement belts and that the current industry standard for securement belts is a 1-inch polyester belt. Finally, you stated that the 1-inch polyester belts have less stretch than the 1.8-inch nylon belts and that the 1-inch belts are easier and less cumbersome to connect to a wheelchair.
Paragraph S4.2(a), FMVSS 209, provides that seat belt webbing cannot be less than 1.8 inches wide, "except for portions that do not touch a 95th percentile adult male with the seat in any adjustment position and the seat back in the manufacturer's nominal design riding position . . . ." That means that seat belt webbing must be at least 1.8 inches wide whenever it touches the person of the seat occupant. The width of webbed wheel chair securement belts that do not touch the persons of the chair occupants is not specified in any standard. Therefore, wheel chair securement belts can be 1 inch or some other width, so long as they do not touch the persons of the chair occupants and meet the other requirements of applicable standards.
I hope this clarifies this matter for you. If you have any further questions or need any further information, please feel free to contact Walter Myers of my staff at this address or at (202) 366-2992.
Sincerely,
John Womack Acting Chief Counsel
ref:209#222#571 d:11/23/93