Interpretation ID: nht95-3.69

TYPE: INTERPRETATION-NHTSA

DATE: August 3, 1995

FROM: Thomas K. O'Connor -- Chief of Maintenance and Operations, Metropolitan Water Reclamation District of Greater Chicago

TO: Office of the Chief Counsel -- NHTSA

TITLE: Verification of Seat Belt Regulations for Step Vans Over 10,000 Pounds GVW-Federal Motor Vehicle Safety Standards (FMVSS) 207, 208, 209, and 210

ATTACHMT: ATTACHED TO 10/11/95 LETTER FROM JOHN WOMACK TO THOMAS K. O'CONNOR (A43; STD. 208)

TEXT: We are requesting written verification on the type of seat belt needed for our step van vehicles in order to comply with FMVSS 207, 208, 209, and 210. At issue is whether a lap-only seat belt versus a shoulder harness seat belt is needed for compliance. In a phone conversation between members of our respective staffs, we were informed that a lap-type belt would comply. We were further informed that written verification of this could be obtained by writing to your office.

In our field work, we use step vans with a Gross Vehicle Weight over 10,000 pounds, equipped with two front seats, a passenger's seat and a driver's seat. The passenger's seat is mounted on a metal pedestal which allows the seat to tilt forward, making e asier access to the rear. The driver's seat is stationary. If both the passenger and driver seats are certified by the manufacturer to comply with FMVSS 207, 208, and 210 when properly installed, and if a certified seat belt (FMVSS 209) is properly ins talled, the question arose as to whether a lap-only seat belt would comply with FMVSS 207, 208, 209, and 210, or whether a shoulder harness type belt had to be used.

If there are any questions concerning our request for written verification on this matter, please contact Sally Yagol of my staff at (708) 222-4080, from 7:00 a.m. to 3:00 p.m., CST, Monday-Friday.

Thank you for consideration.