Interpretation ID: aiam0539
Project Engineer
Brockway Motor Trucks
Factory & General Office
106 Central Avenue
Cortland
NY 13045;
Dear Mr. Massey: This is in reply to your letter of September 12, 1972, regarding th application of S4.3 of Standard No. 207, Seating Systems, to an auxiliary folding seat installed in Brockway trucks.; As shown in your drawings and photographs, the seat faces forward an has a hinge at the rear of the lower cushion. An upward force at the front of the lower cushion will move the cushion upward and rearward until it presses against the seat back.; The intent of S4.3 is to reduce the forces acting on an occupant in a accident by preventing the seat or seat back from folding onto him. It does not appear from the material you have submitted that any motion of the lower seat cushion will impose such additional forces on an occupant. The folding action is therefore not of the type contemplated by the standard and no restraining device would be required for this seat.; Sincerely, Richard B. Dyson, Assistant Chief Counsel