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Technical bulletins (CoF)

3 Rear seatbelts as aisle obstructions in passenger service vehicles

Vehicle inspection requirements manual references

This bulletin gives guidance to vehicle inspectors in applying the following requirements in the VIRM: In-service certification (WoF and CoF):


This document applies to people-mover vehicles, such as Toyota Previas, that are used as passenger service vehicles (PSVs) and have factory-fitted seats and seatbelts that comply with approved seat and seatbelt standards.

Safety concern

Practical tests have been carried out by the Low Volume Vehicle Technical Association (LVVTA) to investigate the concern that rear seatbelts fitted to Toyota Previa vehicles may obstruct passengers in the rear row of seats from exiting the vehicle in an emergency. Results show that seatbelts fitted in these types of vehicle may cause a minor nuisance but not an obstruction; passengers in the rear row of seats can still exit in a reasonable manner in emergency situations.


Factory-fitted seatbelts in people-mover vehicles operated as PSVs should not be considered as obstructions to the aisle provided:

a) seats and seatbelts are original equipment fitted by the manufacturer, and

b) the seatbelt that crosses the aisle is of a retractable type, and

c) the seats, seatbelts and their installation are unmodified (other than minor trimming of the seatback width to achieve the required aisle width), and standards compliant if applicable.

This concession does not apply to:

  • fold-down seats encroaching on aisle space
  • vehicles that are retrofitted with additional and/or modified seat and seatbelt arrangements. Disconnecting or disabling seat rotation mechanisms is not considered to be a modification.

These vehicles must comply with all PSV requirements, such as aisle width.