Interpretation ID: nht78-3.19

DATE: 04/05/78

FROM: AUTHOR UNAVAILABLE; F. Berndt for J. J. Levin, Jr.; NHTSA

TO: Grumman Flxible Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your recent letter asking whether Safety Standard No. 209, Seat Belt Assemblies, and Safety Standard No. 210, Seat Belt Anchorages, would be applicable to a Type I seat belt assembly used as a securement device for wheelchairs in an urban transit bus.

Safety Standard No. 209 is an equipment standard that is applicable to any seat belt manufactured for use on passenger cars, multipurpose passenger vehicles, trucks or buses. Therefore, the seat belt in question would have to comply with the performance requirements of that standard.

Safety Standard No. 210, however, only specifies requirements for seat belt anchorages at the driver's position on buses. Since the assembly you are concerned with would be at a passenger seating position in the bus, it would not have to comply with the anchorage requirements of Standard No. 210.

SINCERELY,

GRUMMAN FLXIBLE CORPORATION

February 10, 1978

Office of the Chief Counsel National Highway Traffic Safety Administration

Attention: Hugh Oats

Dear Mr. Oats:

The Grumman Flxible Corporation is using an extra-long, Type 1 seat belt as a wheelchair securement device in association with the wheelchair accessibility option required by 49 CFR 609.15(c) for installation in urban transit buses. This seat belt is used in conjunction with an adjustable, padded arm extending from the vehicle wall area which can be positioned in front of the forward facing wheelchair passenger.

Is this seat belt subject to the requirements of FMVSS No. 209, Seat Belt Assemblies?

Is the anchorage for this seat belt assembly, installed in a transit bus at a location other than at the driver's position, subject to the requirements of FMVSS No. 210, Seat Belt Assembly Anchorages?

We appreciate very much your assistance with the above.

R. L. Ratz, P.E. Product Safety Engineering