Interpretation ID: aiam2441
Vice President and General Manager
Kustom Fit of Ohio
Inc.
P.O. Box 216
Pioneer
OH 43554;
Dear Mr. Rupp: This responds to your April 30, 1976 request for confirmation tha 'liability' for the correct location of a vehicle's seating reference point (SRP) lies with a vehicle manufacturer or alterer that installs seating and not with the manufacturer of the seat. I regret that we have not responded to your request sooner.; >>>'Seating reference point' is defined by NHTSA regulations (49 CFR 571.3) to mean --; . . . .the manufacturer's design reference point which -- (a) Establishes the rearmost normal design driving or riding positio of each designated seating position in a vehicle,; (b) Has coordinates established relative to the designed vehicl structure,; (c) Simulates the position of the pivot center of the human torso an thigh, and; (d) Is the reference point employed to position the two dimensiona templates described in SAE recommended Practice J826, 'Manikins for Use in Defining Vehicle Seating Accommodation', November 1962.<<<; While the term 'manufacturer' found in the beginning of this definitio could refer to either a vehicle or equipment manufacturer under the relevant statutory definition (15 U.S.C. & (sic) 102(5)), the references in subparagraphs (a) and (b) make clear that the SRP is a location established with reference to the vehicle structure. It is a commonly understood reference point for specifying the available space for a seated occupant within a vehicle. The only exception to this relationship to the vehicle has been in the case of Standard No. 222, *School Bus Passenger Seating and Crash Protection*, where the NHTSA has indicated it would accept an SRP designation that is established with reference to the seat frame. This policy is limited to school buses where seat placement within the vehicle is subject to more variation than in other vehicle types.; This means that the NHTSA, in verifying the compliance of a vehicl with a standard such as Standard No. 210, *Seat Belt Anchorages*, will ask the vehicle manufacturer for the location of the SRP.; Sincerely, Frank A. Berndt, Acting Chief Counsel