Interpretation ID: aiam3084
Freedman Seating Company
400 Academy Drive
Northbrook
IL 60062;
Dear Mr. Wahls: This responds to your recent letter asking how much deflection o deformation of seat belt anchorages is allowed under the requirements of Safety Standard No. 210, for anchorages that are attached to or are a part of revolving pedestal seats. You mention cases in which seat bases deflect so much that the seat touches the floor before the forces required by the standard are attained.; As noted in your letter, paragraph S4.2.3 of Safety Standard No. 21 specifies that permanent deformation or rupture of a seat belt anchorage or its surrounding area is not considered to be a failure, if the required force is sustained for the specified time. Likewise, the agency has stated in the past that the force requirements of Safety Standard No. 207, *Seating Systems*, allow some deformation of the seats during the force test, *provided* structural integrity of the seats is maintained.; Although Safety Standard No. 210 would allow some deformation of th seat base for anchorages that are part of pedestal seats, the structural integrity of the seats would have to be maintained during the force test. Further, you should note that Safety Standard No. 207 requires the forces for testing seats and the forces required by Safety Standard No. 210 to be applied simultaneously for seats that have belt assemblies attached to them. Thus, the pedestal seats discussed in your letter would have to maintain their structural integrity when subjected to the combined forces required by both standards. The agency would not consider pedestal seats to be in compliance with these requirements, if the seats are displaced to an extent that the agency determines occupant safety is threatened.; I hope this letter has clarified the agency's position regarding th force requirements of both Safety Standard No. 210 and Safety Standard No. 207.; Sincerely, Frank Berndt, Chief Counsel