Interpretation ID: nht80-4.22

DATE: 12/02/80

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Seats Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your October 31, 1980, letter asking a question about the appropriate test force for school bus seat belts. In particular, you ask whether seat belts mounted on a seat frame that employ a common U-Bolt would be tested separately or simultaneously.

As you are aware, the agency issued an interpretation stating that for purposes of complying with Standard No. 222, School Bus Passenger Seating and Crash Protection, seat belts mounted on a school bus seat frame can be tested separately as long as they have separate anchorages. In that interpretation, the agency indicated that it would not consider the seat to be a common anchorage when testing school bus seat belts.

If I understand your letter correctly, your seat frame has separate anchorage holes in it. However, the inside portions of the two seat belt systems would be tied together by a common U-Bolt. If this is the means by which you will manufacture your school buses, the seat belts must be tested simultaneously. The use of the U-Bolt provides a common anchorage between the two seat belt systems which require simultaneous testing.

Seats

October 31, 1980

Roger Tilton U.S. Department of Transportation National Highway Traffic Safety Administration

Dear Mr. Tilton:

I am requesting further clarification on FMVSS Standard 222, school bus seating, in the area of seat belt load requirements as outlined in FMVSS Standard 210.

It is my understanding that the simultaneous load testing for two passenger seats is not required but that the 5,000-pound force must be tested at each seating position as long as each seating position provides its own anchorage holes for seat belt mounting.

The clarification of this ruling I am requesting is: on a two-passenger seat, in the metal frame construction, there are holes or provisions for individual mounting of seat belts. If a person mounted these two seat belts in the center by means of a "U-Bolt" sliding the belts on the "U" and then attaching the two nuts, would this means still fall under the above mentioned requirements?

Harold J. Van Duser Engineering U.S. DEPARTMENT OF TRANSPORTATION NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION

OCT 27 1980

Mr. Harold Van Duser Seats, Inc.

Dear Mr. Van Duser:

Pursuant to your telephone request of October 15, 1980, asking for information relating to the test requirements for seat belts in school buses. I am enclosing a previous agency interpretation specifying the required test forces. If I can be of further assistance, please contact me.

Roger Tilton