Interpretation ID: aiam3543
Mazda (North America)
Inc.
23777 Greenfield Road
Suite 462
Southfield
MI 48075;
Dear Mr. Nakaya: This responds to your letter asking a number of questions concernin the definition of Seating Reference Point (49 CFR 571.3). Your letter indicates that the questions arise from a concern that the definition may limit rearward seat track travel.; The agency recently published, in response to petitions for rulemaking an advance notice of proposed rulemaking (ANPRM) concerning the definition of Seating Reference Point. Among other things, the preamble to the notice explains that while the definition of Seating Reference Point establishes limitations on where manufacturers must locate that point, it does not prevent manufacturers from extending seat track travel behind the point. We have enclosed a copy of that notice for your convenience.; Your first question asks for an interpretation of the definition o Seating Reference Point. Among the interpretations you suggest, the one which is most nearly correct is the one which says the Seating Reference Point is the single self-determining point (no choice for the manufacturer) where the 90th percentile two- dimensional manikin should be positioned according to the SAE J826.; The enclosed notice explains that section (d) of the definition o Seating Reference Point requires manufacturers to use the 90th percentile template described in SAE Recommended Practice J826 in locating the Seating Reference Point. While manufacturers must use that template in locating the Seating Reference Point, there is some small leeway (using that device) as to where the point may actually be located. Thus, while your interpretation is partially correct, it is not correct to the extent that it suggests that there is no choice (as opposed to a limited choice) for the manufacturer.; The rest of your questions appear to involve the same issue, i.e. which version of an SAE Recommended Practice to use when a safety standard incorporates by reference an SAE Recommended Practice that has later been updated by SAE. The version which must be used is the one actually referenced by the standard. The fact that SAE updates one of its Recommended Practices does not change a Federal motor vehicle safety standard that incorporates an earlier version. Such a change would require the same type of rulemaking as any other amendment.; We believe that you will be able to answer your questions based on th foregoing discussion and the enclosed notice.; Sincerely, Frank Berndt, Chief Counsel