Interpretation ID: nht71-3.49

DATE: 07/22/71

FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: Recreational Vehicle Institute

TITLE: FMVSS INTERPRETATION

TEXT: By letter of May 26, 1971, you requested our interpretation of S7.2.3 of Standard No. 208, Occupant Crash Protection, as it affects motor homes and campers that have a forward control configuration. The section provides that forward control vehicles under 10,000 pounds GVWR manufactured after August 15, 1977, may continue to use seat belt assemblies and used not provide passive protection, but that motor homes and vehicles carrying chassis-mount campers must provide passive protection, at least in head-on impacts. Your question is whether a motor home or chassis-mount camper that is also a forward control vehicle must provide passive protection.

The exemption granted by S7.2.3 to forward control vehicles was based on the difficulties inherent in providing adequate passive protection for(Illegible Word) vehicles, regardless of their anticipated use. If a forward control vehicle is manufactured in the form of a motor home or camper, the exemption continues to apply and such a vehicle would not be required to conform to the passive protection requirements of S4.1.2.2.

Please advise us if you have further questions on this subject.