Interpretation ID: nht92-3.35

DATE: 10/01/92

FROM: JESS R. THURMAN

TO: MARY VERSAILLES -- OFFICE OF CHIEF COUNSEL, NHTSA

ATTACHMT: ATTACHED TO LETTER DATED 11-16-92 FROM PAUL J. RICE TO JESS R. THURMAN (A40; STD. 207; STD. 208; STD. 209; STD. 210)

TEXT: On September 23, 1992, I talked to Mr. Jim Gilkey in the engineering department of National Highway Safety Admn. about moving seats and seat belts in a new Van. He informed me that he did not know the complete law on this. He advised me to write to you about this and explain my problem. He said that maybe each handicap case could be reviewed and some change could be made.

I am a disabled veteran confined to a wheelchair, wanting to buy a new Ford Van converted to my use with a wheelchair lift. I now have a 83 Ford Van with a lift. The two passenger captains chairs are moved back to make room for my wheelchair to enter. The bench seat is moved to the rear as for as it will go when lying down or up right. This makes it possible to keep all the seats in the Van for my family & I to take trips. This was all done before the law was passed that the seats & belts could not be moved. The chairs in my Van have floor seat belts, so it was no problem to move them.

With the new Vans, the three point hitch safety belts can not be moved according to law. Van Conversion Companies will not move the seat belt hook up, nor will the ford dealer.

If I have the two seats out, all I would have left is a bench seat for three people in the rear. It would be a shame to spend all this money for a Van and loose two seats.

If the two passenger captain chairs could be moved back about 30 inches and the seat belt hook up moved to match the chairs, this could all be done at the Van conversion plant. This way the seat and belts would be okay and safe.

My question is this, can these three point seat belts and chairs be moved back? If this could be moved may I have a letter to confirm that this can be done so that when I purchase a new Van I can take the letter and they can follow your instructions.

If you have any questions, please feel free to call me at 812-867-2857.

Thank you for your assistance in this matter.

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