Interpretation ID: 1984-2.22

TYPE: INTERPRETATION-NHTSA

DATE: 07/06/84

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Toyota Motor Corporation

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. J. Kawano General Manager, U.S. Office Toyota Motor Corporation One Harmon Plaza Secaucus, New Jersey 07094

Dear Mr. Kawano:

This letter replies to your request for an interpretation of FMVSS No. 202, Head Restraints. Your first question concerns the measurement of the lateral width of a head restraint with a "Volvo-type configuration." The drawing attached to your letter appears to depict an adjustable head restraint with a rectangular shape and a hollow center. Paragraph S4(b) of Standard No. 202 requires measurements, according to S4(b)(1) and (2), to be made when the head restraint is "adjusted to its fully extended design position." The lateral width of the head restraint of a individual or bucket seat may be measured either 2.5 inches below the top of the restraint or 25 inches above the seating reference point. These are the only two locations at which this measurement may be made. The lateral width may not be measured at part B on your drawing, because B is not the correct location at which to make this measurement. A copy of this drawing is enclosed for your convenience.

Your letter and drawing indicate a concern that, if the lateral width is measured 2.5 inches below the top of the restraint, the hollow space between the two sides of the rectangular head restraint may not be included in measuring the total width. Using the information you have supplied, we believe that the lateral width of this type of head restraint, measured either 2.5 inches below the top of the restraint or 25 inches above the seating reference point, would include the hollow space, if the hollow space occurs at either location. The lateral width would also include, of course, the widths of both sides of this restraint, marked A1 and A2 in your drawing. This lateral width may or may not equal the width, B, located at the top of the restraint in your drawing.

Your second question regarding the correct demonstration procedure to test compliance with Standard No. 202 is answered by the language of paragraph S5.2 of the standard. This paragraph states that, if the head restraint conforms to S4(b), compliance is demonstrated in accordance with S5.2 with the head restraint in its fully extended design position. The dynamic testing procedure would not be required, unless your head restraint conforms to paragraph S4(a). The manufacturer has the option of designing a head restraint which meets the performance requirements of either paragraph S4(a) or paragraph S4(b).

Sincerely,

Frank Berndt Chief Counsel

Enclosure

January 26, 1984

Mr. Frank A. Berndt Chief Counsel National Highway Traffic Safety Administration NOA-30 400 Seventh Street, S.W. Washington, D.C. 20590

Dear Mr. Berndt:

SUBJECT: Toyota' s Request for Interpretation Regarding Std. 202, "Head Restraints," S4(2) (i) and (ii)

In reference to the above subject matter, Toyota requests clarification of the specified head restraint width.

In FMVSS 202, S4(b), the lateral width of the head restraint is required as follows:

"When measured either 2.5 inches below the top of the head restraint or 25 inches above the seating reference point, the lateral width of the head restraint shall not be less than (i) 10 inches for use with bench-type seats; and (ii) 6.75 inches for use with individual seats."

Our question is as follows: If the head restraint has a Volvo-type configuration (see Attachment), which part is used to measure the lateral width? A or B? We believe that B should represent the lateral width of this head restraint. Therefore, if the lateral width B is more than 6.75 inches (individual seat), we believe that the dynamic test (FMVSS 202, S4(a)) is not required.

Please review the attached drawing and inform us of the correct area to measure for width of the head restraint. Your prompt response would be greatly appreciated.

Thank you.

Sincerely,

TOYOTA MOTOR CORPORATION

J. Kawano General Manager U.S. Office

JK:KY:gcm Enclosure -

"INSERT"

VOLVO-TYPE Head Restraint