Interpretation ID: nht75-4.32

DATE: 04/25/75

FROM: AUTHOR UNAVAILABLE; J. C. Schultz; NHTSA

TO: Brougham Industries

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your March 17, 1975 request for an explanation of the seat belt assembly installation requirements of Standard No. 208, Occupant crash protection, as they apply to motor homes with a gross vehicle weight rating (GVWR) of more than 10,000 pounds, and those with a GVWR of 10,000 pounds or less.

The standard requires that motor homes with a GVWR of more than 10,000 pounds be equipped with "passive" crash protection of a certain level (S4.3.1) or a Type 1 or Type 2 seat belt assembly at each designated seating position (S4.3.2).

Motor homes with a GVWR of 10,000 pounds or less must be equipped with "passive" crach protection of a certain level (S4.2.1.1) or a Type 2 seat belt assembly at each outboard designated seating position that includes the windshield header within the head impact area, and a type 1 or Type 2 seat belt assembly at each other designated seating position (S4.2.1.2).

At the front outboard designated seating position, you state that the incomplete vehicle manufacturer provides Type 1 seat belts. Unless the documentation, provided under Part 568 of our regulations (49 CFR Part 568), states that modification of the Type 1 seat belts is required to meet Standard No. 208, it appears that the vehicle windshield header is not within the head impact area and that Type 1 seat belts meet the requirement.

You point out that some manufacturers may not provide as many designated seating positions as there are sleeping accommodations in the vehicle. We evaluated the proportion of this problem recently because of the possibility that occupants were not being provided with enough Type 1 seat belts. An informal but comprehensive survey at a recent trade show indicated that the problem is extremely limited. If you have information that this practice is becoming more common, please provide this office with more specific identification of manufacturer and model line.

We do appreciate your efforts to provide your purchasers with a high level of crash protection.

SINCERELY,

BROUGHAM

March 17, 1975

Administrator National Highway Traffic Safety Administration U. S. Department of Transportation

Brougham Industries, Inc. has been manufacturing Class C Motor Homes on chopped Van chassis with GVWR of 10,000 pounds or less since 1970. In compliance with Federal Motor Vehicle Safety Standards and Regulations, part 571; S208 paragraphs S 4.2, S 4.2.1 and S 4.2.1.2, Brougham has been installing type 2 seat belts in the forward outside passenger and driver seats where windshield header contact is possible. Type 1 seat belts have been installed in the aft seats to bring the total seats suitable for occupancy while moving to advertised sleeping capacity of the vehicle i.e., 6 to 8. This costs Brougham approximately $ 80.00 to $ 100.00 per coach.

Our competitive surveys indicate Winnebago, Mobile- Traveler, Midas, Fleetwood, Open Road and the majority of the competition are using type 1 seat belts that come with the forward control truck chassis for the driver and forward passenger. Aft passenger seat belt installations vary from all seats equipped with type 1 seat belts to all seats placard against use while the vehicle is in motion.

Brougham desires to comply with the spirit as well as the letter of the Safety Standards, but this added $ 80.00 to $ 100.00 cost per vehicle places the company at a disadvantage in the market place.

Please give me an official interpretation of this regulation as it applies to motor homes of 10,000 pounds and less and over 10,000 pounds so that I can incorporate the correct design criteria in our product.

John S. Knaur, Jr. Corporate Engineer

cc: CARLOS FLORES -- SMALL BUSINESS ADMIN.