EvoBus GmbH - Comments

Dear Sir or Madam, Regarding the NPRM FMVSS 210 Seat Belt Assembly we would like to inform you of two subjects which from our point view need some clarification. 1. Use of FAD-2 Due to the special situation in buses/coaches it would be preferable if for double seats in coaches the use of FAD-2 would be the general rule. In coaches the situation regarding shoulder width is always similar to the one you find on rear seats of passenger cars which is the given example for the use of FAD-2. To avoid misinterpretations a clear wording would be preferred. 2. Either the text or the drawings should be amended in order to show more clearly where the forces are to be applied. The bridged pull yoke which represents the point of application of the forces should be explicitly marked to ease the understanding and preparation of the test. 3. Regarding the proposed lead time of three years we consider this too short due to life cycles of current seatings. A 5 year lead time would be preferable. We hope to have expressed our comments to your satisfaction and are prepared to assist with any further information you may need. Best Regards Thomas Gold EvoBus GmbH