Interpretation ID: nht88-4.36

TYPE: INTERPRETATION-NHTSA

DATE: 12/09/88

FROM: KEITH A. MCDOWELL -- VICE PRESIDENT -- ENGINEERING TRANSPORTATION PRODUCTS GROUP AMERICAN SEATING CO

TO: OFFICE OF THE CHIEF COUNSEL NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 03/22/89 FROM ERIKA Z. JONES -- NHTSA TO KEITH A. MCDOWELL, REDBOOK A33, STANDARD 208, STANDARD 209, STANDARD 210; LETTER DATED 02/25/89 FROM KEITH A. MCDOWELL TO NHTSA

TEXT: Honorable Chief Counsel:

My name is Keith McDowell and I am employed by the American Seating Company as Vice President of Engineering. For your information American Seating is the leading manufacturer of large transit bus seating on the North American Continent. We have long b een an advocate of passenger safety, and our continued concern for safety is evidenced by this letter.

Recently, we have received a number of inquires from bus builders regarding the provision of seat belts on our seats. (It is our belief that this trend is the result of concern generated in the school bus market.) Upon reviewing the current Federal Moto r Vehicle Safety Standards, we find that no seat belt standards apply to passenger seating on large buses over 10,000 pounds GVW. We are currently at a loss as to how to respond in a responsible manner to our customers.

Inquiries from bus builders are generated when a Transit Authority specifies a requirement for seat belts on transit bus bid documents. These procurements are typically 80% funded by the Urban Mass Transit Administration (no doubt, a familiar agency). Unfortunately, no bid specifications outline the standards to use for design and testing of seat belt installations.

Because of the continuing demand from our customers, we are requesting you to provide us guidelines for the design and installation of seat belt assemblies on large buses (over 10,000 pounds GVW). Specifically, these guidelines must address transverse s eat installations (forwarded facing and rearward facing) and longitudinal seat installations (aisle facing).

As you well understand, our need is of the utmost urgency as current bids are involved. It is our opinion that federally funded bus procurements specifying seat belts must include guidelines for belt installation and testing so that all suppliers may bi d competitively, fairly, and above all else, with utmost regard for the safety of the public.

We look forward to your timely response.

Sincerely,