Forward facing made to measure seating with 3 point seat belts

[Lenny HB]

That is official government guidance and says at the top it was published in May 2010.



View attachment 873001

The regulation they refer to is 1986 it says seat belts aren't required in the back and even covers belts on side facing seats, it's well out of date.

 

[JRT]

The regulation they refer to is 1986 it says seat belts aren't required in the back and even covers belts on side facing seats, it's well out of date.

Ok if you say so, but where is the updated guidance.

 

[Lenny HB]

Ok if you say so, but where is the updated guidance.

Not a clue.

 

[L' Hobo]

I think you're right....it's pretty much a free for all so long as it all stays good ( you'll be bollocks'ed if it goes wrong).....except for kids and seat belts, that are need for kids and should be certified ones ( really are there any other than...?).

When I had seatbelts fitted ( to comply with a new School Contract) to a Double Deckers seats some years ago, I had to drive it to a Certificated Company in Lincoln, from Surrey, to have them fitted before the insurance company would cover.
They reinforced floor sections and anchor points before issuing certificate of conformity.

Not sure if it applies to private vehicles?

 

[JRT]

Seems very strange to me that the only guidance I can find is that one.

Out of interest can anybody locate anything more recent from an official source?

I will shortly be helping a good friend do similar to the OP and we could do with the definitive line on this.

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[JRT]

When I had seatbelts fitted ( to comply with a new School Contract) to a Double Deckers seats some years ago, I had to drive it to a Certificated Company in Lincoln, from Surrey, to have them fitted before the insurance company would cover.
They reinforced floor sections and anchor points before issuing certificate of conformity.

Not sure if it applies to private vehicles?

I think the key factor there is possibly the carrying of children (school contract).

 

[RedFrame]

Most if not all of the seat swivels available have never been certificated. Not sure how they would stand up to a good(bad) accident.

Absolute piffle, where did you get that information.

Attached the first four swivel bases found online,  all certified, I can't be bothered searching any more.

Cheers
Red.

 

[ianp]

Seems very strange to me that the only guidance I can find is that one.

Out of interest can anybody locate anything more recent from an official source?

I will shortly be helping a good friend do similar to the OP and we could do with the definitive line on this.

Converting a vehicle into a motor caravan (motor home)

What DVLA expects to see when considering your application to change the body type description on your V5C registration certificate (log book) to motor caravan.

www.gov.uk

Internal features for motor caravans

Guidance on the required internal features for motor caravans.

www.gov.uk

Vehicle manufacturing and modification - GOV.UK

The law on converting or making modifications to vehicles, vehicle manufacturing classification.

www.gov.uk

 

[JRT]

Converting a vehicle into a motor caravan (motor home)

What DVLA expects to see when considering your application to change the body type description on your V5C registration certificate (log book) to motor caravan.

www.gov.uk

Internal features for motor caravans

Guidance on the required internal features for motor caravans.

www.gov.uk

Vehicle manufacturing and modification - GOV.UK

The law on converting or making modifications to vehicles, vehicle manufacturing classification.

www.gov.uk

Thanks for that, he has got them.

There doesn't appear to be anything much if at all said about fitting belts to added seating though.

I'll recommend he emails the email addy in the link I posted.

 

[L' Hobo]

I think the key factor there is possibly the carrying of children (school contract).

Possibly but I think it was because the vehicle was a Commercial one and used on other work too. At least that was what the insurers inferred?

Strangely though, on Double Deckers, seatbelts are not a requirement of law but they are on some single Deckers.

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[Boldly]

Absolute piffle, where did you get that information.

Attached the first four swivel bases found online,  all certified, I can't be bothered searching any more.

Cheers
Red.



View attachment 873037

View attachment 873038

View attachment 873039

View attachment 873040

Can't remember which self build site I read it on. I believe there is no certification system to cover these. A CE no is an EU number I think? No longer applicable to UK?
Apologies if I recollect incorrectly. Also don't some a frame manufacturers quote a CE number?

 

[RedFrame]

Can't remember which self build site I read it on. I believe there is no certification system to cover these. A CE no is an EU number I think? No longer applicable to UK?
Apologies if I recollect incorrectly. Also don't some a frame manufacturers quote a CE number?

Ahhh, yes, that would explain it. I joined one of those when I first started building my van, I have to say that the "resident electrical expert" was as knowledgeable in smart alternators and lithium as a Carp is at hunting Drop Bears (I should've put the membership fee into Willy Wonka's Chocolate Teapot Investment Fund), the guys on here Raul Lenny HB Ditcha and more, were all far more knowledgeable, helpful and friendly.

Can't remember which self build site I read it on. I believe there is no certification system to cover these. A CE no is an EU number I think? No longer applicable to UK?
Apologies if I recollect incorrectly. Also don't some a frame manufacturers quote a CE number?

A simple search turned this up from the Gov.uk site.

"the UK Government announced on 1 August 2023 that it will indefinitely recognize the EU's product conformity assessment mark (the “Conformité Européenne” or “CE” mark), with respect to a range of manufactured goods placed on the UK market."

16 Aug 2023

Can't remember which self build site I read it on. I believe there is no certification system to cover these. A CE no is an EU number I think? No longer applicable to UK?
Apologies if I recollect incorrectly. Also don't some a frame manufacturers quote a CE number?

I have no idea, see above.

Cheers
Red.

 

[JRT]

Can't remember which self build site I read it on. I believe there is no certification system to cover these. A CE no is an EU number I think? No longer applicable to UK?
Apologies if I recollect incorrectly. Also don't some a frame manufacturers quote a CE number?

The UKCA designation is set to replace the CE number/designation but at the mo the CE or both is still being used for some items.

 

[Boldly]

I posted originally in support of the op when other posters were querying the legality or otherwise of his design. I merely was trying to point out that the majority of commercially available swivel seats were at best not certificated as advertised. Having been challenged on this I have attempted to find the CE number that would approve such seat swivels. I can only find one company which actually quotes which CE regulation it adheres to(ce96/38) if anyone is interested and this applies to seat belt anchorages not swivel seats. Despite trying to find the CE that covers swivels I can't find it. I don't believe there is one. Anyone able to point me in the right direction?

 

[RedFrame]

I posted originally in support of the op when other posters were querying the legality or otherwise of his design. I merely was trying to point out that the majority of commercially available swivel seats were at best not certificated as advertised. Having been challenged on this I have attempted to find the CE number that would approve such seat swivels. I can only find one company which actually quotes which CE regulation it adheres to(ce96/38) if anyone is interested and this applies to seat belt anchorages not swivel seats. Despite trying to find the CE that covers swivels I can't find it. I don't believe there is one. Anyone able to point me in the right direction?

You again make a statement of fact without Data or a link to credible research, or even your own research (other than you failed to find any supporting information)...

You can continue your claims, I won't respond any more, for me it's important that readers of the forum get good information.

Cheers
Red.

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[JRT]

I posted originally in support of the op when other posters were querying the legality or otherwise of his design. I merely was trying to point out that the majority of commercially available swivel seats were at best not certificated as advertised. Having been challenged on this I have attempted to find the CE number that would approve such seat swivels. I can only find one company which actually quotes which CE regulation it adheres to(ce96/38) if anyone is interested and this applies to seat belt anchorages not swivel seats. Despite trying to find the CE that covers swivels I can't find it. I don't believe there is one. Anyone able to point me in the right direction?

Your post comes directly after mine so I presume perhaps incorrectly you were responding to me. But for clarity I wasn't doubting what you posted I was just pointing out what is set to replace the CE mark.

 

[TheBig1]

Sadly, like any grey area of law, you can get away with a lot till it gets tested in court. With the MOT, it is ridiculous but the mounting points for rear seat belts are required by law, but the test is little more than a tug on a spot welded piece of thin plate to the bodyshell. So long as the tester doesn't see rust it passes. Even 2 washers with a bolt through passes.
It is not illegal to make or fit a diy seatbelt mount. Anything professionally created has to be safe though and if the welds were to fail injuring a passenger in a crash, the insurers WILL go after the manufacturer if they can. So long as the person that buys the frame is not qualified to do the engineering drawings/welding/technical specification, the fault is limited. What trips some up is the type approval and specific legislation of seatbelts for children. Can and is a big can of worms

I like the look of the frame in the OP however it is clearly not complete, as the squab has no obvious support and will allow a belted occupant to submarine out of the belt and get injured if the seat box collapses. Vehicle manufacturers spend millions on crash testing for certification by NCAP etc. If they could get away with Brian knocking up a frame in his shed, because he is a good welder, I am sure they would. Personally I think the company that created this, copying a wooden template are leaving themselves open to be sued and very foolish. There is a lot of science to crash tested frames and plating under the floor for structure looks good, but has it been stress modelled to take account of impacts from any possible direction?

I would like to see what the insurers ask for if they know that this is not an off the shelf product

My experience with insurance companies is that any suggestion it is not backed by indemnity insurance and the assessor after an accident will have it fully inspected and the written specification paperwork poured over by lawyers. Like they do with souped up sports cars

 

[PeterCarole29]

You again make a statement of fact without Data or a link to credible research, or even your own research (other than you failed to find any supporting information)...

You can continue your claims, I won't respond any more, for me it's important that readers of the forum get good information.

Cheers
Red.

I agree and welcome the need for correct information the thread i started has taken twists and turns and thank all for there input and please correct me if i am wrong.
The goverment ackowledge

I like the look of the frame in the OP however it is clearly not complete, as the squab has no obvious support and will allow a belted occupant to submarine out of the belt and get injured if the seat box collapses. Vehicle manufacturers spend millions on crash testing for certification by NCAP etc. If they could get away with Brian knocking up a frame in his shed, because he is a good welder, I am sure they would. Personally I think the company that created this, copying a wooden template are leaving themselves open to be sued and very foolish. There is a lot of science to crash tested frames and plating under the floor for structure looks good, but has it been stress modelled to take account of impacts from any possible direction?

I would like to see what the insurers ask for if they know that this is not an off the shelf product

My experience with insurance companies is that any suggestion it is not backed by indemnity insurance and the assessor after an accident will have it fully inspected and the written specification paperwork poured over by lawyers. Like they do with souped up sports cars

I can help with some info on this specific frame. The original is in my other van. It is a good observation what you see is incomplete as in the seat base. The origin seat is manufacturer specific and plated only has a motorhome timber frame 15mm around it giving it a base for the seat.
I think it could be improved with a steel box frame which i will be having made, I have used 25mm motorhome ply glued and bonded.
I agree when in an accident there are many transverse forces.
I think anyone doing a self build will potentially be leaving themselves open to WHAT If.

After reading all linked posts am i correct that theres nothing specific to say your seat frame has to be certified have an CE mark or the like, But must be of a good standard and fit for purpose (wether you agree this is good or not)

The UKCA mark would be to do with us leaving the EU
The insurance question I,m sure your right if there was such an incident that a passenger was injured in the seat
This for us will never happen with us and in view of the replies here think it prudent if we ever sell the van remove the seat belts inform the buyer of potential implications if they carry passengers

 

[L' Hobo]

See my post on another thread concerning the death of 2 children and Mother.

 

[PeterCarole29]

See my post on another thread concerning the death of 2 children and Mother.

Yes I did and posted saying If we had Spanish regulations it would not have happened and I would welcome them does that have any relivence to a professionally made not certified and competently fitted forward facing double seat with CE marked 3 point seat belts thread

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[CAB96]

Unless there is a specific legislation, and items fall under the scope of the legislation, there won't (shouldn't) be a CE (or UKCA) mark.

As said, presumably the seat belt anchors fall within the scope of one of the Directives or Regulations, but not swivel seats. (I'll have a look later).

It is usually a criminal offence to apply a CE (or UKCA) mark to an item that should not or cannot be marked, i.e. does not require the marking.

 

[PeterCarole29]

Unless there is a specific legislation, and items fall under the scope of the legislation, there won't (shouldn't) be a CE (or UKCA) mark.

As said, presumably the seat belt anchors fall within the scope of one of the Directives or Regulations, but not swivel seats. (I'll have a look later).

It is usually a criminal offence to apply a CE (or UKCA) mark to an item that should not or cannot be marked, i.e. does not require the marking.

For my own information I have concluded correct me if i am wrong.
The 3 point seat belt itself needs to be CE or equivelent but so far no regulation so far stipulating the seat frames
However there are crash tested one available

 

[TheBig1]

For my own information I have concluded correct me if i am wrong.
The 3 point seat belt itself needs to be CE or equivelent but so far no regulation so far stipulating the seat frames
However there are crash tested one available

My understanding of the current situation is that you are correct. Hence my point about the anchor points and MOT testing. It is all very vague with an implication you need to adhere to the construction and use regulations, but even that has gaps

Seat swivels are an accessory installed on a seat that has already been crash tested and clearly invalidates the original certification. But most of us accept the risk, based on improved functionality. The CE certification for a few swivels comes from that design being OEM in some MPV vehicles, so the inherent design has been tested. I believe the difference between the designs is how the top and bottom plates is attached allowing the swivel action. Some have a single large diameter bolt, others a large bearing welded to each plate

Seat frames are a very grey area, as it is the belt and anchorage that is tested

 

[L' Hobo]

My understanding of the current situation is that you are correct. Hence my point about the anchor points and MOT testing. It is all very vague with an implication you need to adhere to the construction and use regulations, but even that has gaps

Seat swivels are an accessory installed on a seat that has already been crash tested and clearly invalidates the original certification. But most of us accept the risk, based on improved functionality. The CE certification for a few swivels comes from that design being OEM in some MPV vehicles, so the inherent design has been tested. I believe the difference between the designs is how the top and bottom plates is attached allowing the swivel action. Some have a single large diameter bolt, others a large bearing welded to each plate

Seat frames are a very grey area, as it is the belt and anchorage that is tested

And that is the difference between expensive swivels and cheaper ones.
Sadly, often, DIY converters go for the cheaper version!

 

[gus-lopez]

I think the key factor there is possibly the carrying of children (school contract).

No they were introduced because the law before was an ass in allowing coaches carrying school children under the age of 14 to sit 3 to a double seat! Absolute nonsense. I.e a 50 seater coach could legally carry 75 under 14's. When I found out about it from my girls & queried it with the school & police they agreed with me but said that they could do nothing at that time as the law allowed it.

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[PeterCarole29]

And that is the difference between expensive swivels and cheaper ones.
Sadly, often, DIY converters go for the cheaper version!

Out of interest ,How many DIY conversions have you seen or known about that have used the cheap ones and what do you call cheap. As thats quite a bold statement . I am guessing theres an awful lot more responsable DIY converters that buy the branded swivels than you think.
To save you looking at prices you can buy a branded make thats sold direct to the Factory motorhome converters for £140. Which is not expensive. FASP swivels i believe are Italian and sold to Factory converters .This is what the company i bought mine from emailed me back today saying

 

[L' Hobo]

Out of interest ,How many DIY conversions have you seen or known about that have used the cheap ones and what do you call cheap. As thats quite a bold statement . I am guessing theres an awful lot more responsable DIY converters that buy the branded swivels than you think.
To save you looking at prices you can buy a branded make thats sold direct to the Factory motorhome converters for £140. Which is not expensive. FASP swivels i believe are Italian and sold to Factory converters .This is what the company i bought mine from emailed me back today saying

Genuine OE Fiat 2007 drivers seat swivel from Coastal is about £1000. That's what I call expensive!

 

[PeterCarole29]

Genuine OE Fiat 2007 drivers seat swivel from Coastal is about £1000. That's what I call expensive!

Blimey that is expensive .

 

[PeterCarole29]

They use the same swivel mechanism as the FASP ones and are also made in Italy.
They also want £345 for the seat runners which says it all really

 

[TheBig1]

Now we are touching on the greedy mark up on parts. They use the psychology of customers attributing higher safety to OEM parts oblivious of the fact that those parts are purchased, not manufactured by the vehicle manufacturer or converter.

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