Interpretation ID: nht95-1.57

TYPE: INTERPRETATION-NHTSA

DATE: February 8, 1995

FROM: Mark Warlick

TO: Ed Glancy -- Chief Counsel

TITLE: NONE

ATTACHMT: ATTACHED TO 4/24/95 LETTER FROM PHILIP R. RECHT TO MARK WARLICK (A4; PART 571)

TEXT: Re: FMVSS 208

The attached document is taken from the R.V.I.A. handbook A Guide to FMVSS, April 23, 1991. My questions pertain to item number 3. Is the statement about the minimum number of designated seating positions required as there are sleeping accommodations s till in effect? If so, where can I find it in the October 1, 1993, CFR 49 manual? And, what is the "definition" or "defined area" that makes up one sleeping position?

Attachment

FMVSS 208: Occupant Crash Protection

This standard specifies requirements for both active and passive occupant crash protection systems.

Applicability: Passenger cars, MPVs, trucks, and buses

Requirements: All designated seating positions (DSP) must be belted

1. MPVs with GVWR of 10,000 pounds or less

a. Other than motorhomes: Type 2 at each front outboard DSP; Type 1 elsewhere; warning system for front (See Figure 208-1 for description of Type 1 and 2 seat belts)

b. Motorhomes: Type 1 may be used for front outside DSP, unless windshield header is within head impact area (Type 2 must be used); Type 1 elsewhere; warning system for front

2. MPVs with GVWR of more than 10,000 pounds

Either a Type 1 or Type 2 at each designated seating position

3. There must be a belt at each DSP; it is the NHTSA's position that, as a minimum, there must be as many DSPs as there are sleeping accommodations (if the vehicle actually has that many "seats")

4. "Designated Seating Position": Any plan view location capable of accommodating a person at least as large as a 5th percentile adult female if the overall seat configuration and design and vehicle design is such that the position is likely to be used while the vehicle is in motion

5. Belts must meet the requirements of FMVSS 209