Interpretation ID: nht94-2.19

TYPE: INTERPRETATION-NHTSA

DATE: April 6, 1994

FROM: Ivan L. Bost -- Director Of Engineering, Comm-Trans, The Sully Corporation

TO: Mary Versailles -- NHTSA

TITLE: Federal Ruling On 3 Point Shoulder Harnesses In Rear Outboard Seating Positions In The Vans We Convert For Commercial Use.

ATTACHMT: Attached To Letter Dated 6/8/94 From John Womack to Ivan L. Bost (A42; Std. 208)

TEXT: Dear Ms. Versailles,

We at Comm-Trans manufacture/convert and sell a line of commercially developed vans for use in the commercial shuttle industry. Our customers represent such markets as hotels, churches, limousine co's, airport ground transportation services, rent-a-car co's and non emergency medical transport co's.

My primary question pertains to whether or not 3 point shoulder harnesses are required in the vehicles that we convert that seat from 10 - 15 people including the driver. Please see the specifications and floor plans I have enclosed. The GVWR of the ve hicles in question is in excess of 8500 pounds and less than 10,000 pounds. We as a company have been installing these shoulder harnesses since 1992. The reason for my question is it has recently been brought to our attention at a few of my competitors are not installing shoulder harnesses and are using standard lap belts in the same size and type vans.

I have also talked with Charlie Case in your office and he reinforced what we are doing with the definition of a bus under 571.3 and regulation 208 in section S.4.4.3.2. Please take the time to review this issue and get back with me in writing with a le gal interpretation of the standards.

Thanks for your time and I look forward to hearing from you.

Sincerely,