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TAKE ACTION NOW – ADD YOUR COMMENTS TO SUPPORT Renewal of EMC Seatbelt Exemption Petitions, Due by September 3
In 2022, the National Highway Traffic Safety Administration (NHTSA) granted a 2-year exemption from the 3-point seat belt requirement for side-facing seats on entertainer motorcoaches – it’s time now to renew this exemption. NHTSA recently published and started a 60-day comment period on the requests (petitions) from 13 Entertainer Motorcoach Council (EMC) members to renew the exemption granted in 2022. Comments are due September 3, 2024.
Click here to view the notice
Linked below is a draft letter template that you may use for your comments. All you need to do is open the letter and edit the portions highlighted in yellow and then submit it to NHTSA.
Click here to file comments. Click the “Comment” button and follow the online instructions for submitting comments.
Background
NHTSA previously granted seat belt exemptions to the Hemphill Brothers and 13 EMC Members.
The agency agreed with the manufacturers that an exemption will not impact general motor vehicle safety because the exempted buses will provide overall safety at least equal to that of non-exempted buses. Further, the petitioners each produce a small number of affected vehicles annually.
The exemption permits the petitioners to install Type 1 seat belts (lap belt only) at side-facing seating positions, instead of Type 2 seat belts (lap and shoulder belts) at those positions, on the OTRBs they manufacture. This exemption does not apply to forward-facing designated seating positions on the manufacturers’ vehicles. Under FMVSS No. 208, the forward-facing seating positions must have Type 2 lap and shoulder belts.
Each of the manufacturers must place a label or sticker on the windshield or side window of all vehicles manufactured under this exemption. The sticker is the vehicle’s certification label and should read as follows: “THIS VEHICLE CONFORMS TO ALL APPLICABLE FEDERAL MOTOR VEHICLE SAFETY STANDARDS IN EFFECT IN [Month, Year] EXCEPT FOR THE SHOULDER BELT REQUIREMENT FOR SIDE-FACING SEATS (STANDARD NO. 208, OCCUPANT CRASH PROTECTION) EXEMPTED PURSUANT TO NHTSA EXEMPTION NO. EX-____.”
If you have any questions, please contact ABA General Counsel Rick Schweitzer at rpschweitzer@rpslegal.com or (202) 223-3040 (office) or (703) 946-2548 (mobile).
