Interpretation ID: nht78-3.17

DATE: 09/27/78

FROM: AUTHOR UNAVAILABLE; J. J. Levin, Jr.; NHTSA

TO: Wayne Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your recent letter asking whether Safety Standard No. 208 applies to side-facing seats in multipurpose passenger vehicle vans. You also ask to be advised of the criteria to be used for the installation of seat belts in these vehicles.

Safety Standard No. 208, Occupant Crash Protection, does require side-facing seats in multipurpose passenger vehicles to comply with one of the options under paragraph S4.2.2, since the side-facing seats in question would be considered designated seating positions. If a manufacturer chooses to install seat belts under one of the options of that paragraph, the seat belt assemblies must comply with Safety Standard No. 209, Seat Belt Assemblies, and Safety Standard No. 210, Seat Belt Anchorages.

Safety Standard No. 210 does exempt side-facing seats from its strength requirements, but all other requirements of the standard would be applicable. However, we strongly recommend that belt anchorages for side-facing seats be of at least equivalent strength to anchorages for forward and rearward facing seats, since the strength specifications are only minimum performance requirements. Side-facing seats were excepted from the strength requirements specified in the standard because the forces acting on side-facing seats are different from those acting on forward or rearward facing seats and the requirements and procedures were specifically developed for these latter seats.

Please contact this office if you have any further questions.

SINCERELY,

Wayne Corporation

August 24, 1978

Office of Chief Counsel National Highway Traffic Safety Adm.

Gentlemen:

The Wayne Corporation manufacturers small buses (GVWR 10,000 lbs. and under), Busette and Transette, which have a normal passenger capacity of 16 to 20 passengers.

Some of these buses are equipped to accommodate transporting the handicapped. In some of these cases, the operators' requirements for lifts, wheelchair anchorage devices, side facing seats, etc., reduced the passenger capacity to less than 10 persons, in which case the vehicle becomes, for purpose of Federal Certification, a multipurpose passenger vehicle rather than a bus.

Which, if any, of the requirements of FMVSS 208, Passenger Crash Protection, apply to side facing seats installed in the MPV discussed above?

If you should find that S4.1.2.3 of FMVSS 208 applies at the option of the manufacturer, please advise the criteria to be used for the installation of the seat belts, taking into consideration that all current seat belt requirements relate only to forward and rearward facing seats.

Robert B. Kurre Director of Engineering