Interpretation ID: aiam2872
Southwest Research Institute
6220 Culebra Road
Post Office Drawer 28510
San Antonio
TX 78284;
Dear Mr. Kerr: This responds to your June 27, 1978, letter concerning the requirement of Safety Standard No. 207 as they would apply to pedestal seat assemblies for use in van vehicles. You ask whether your test methodology is consistent with the requirements of the standard and whether the pedestal base is considered part of the seat assembly.; As you know, the agency does not approve a manufacturer's test methods A manufacturer must exercise due care to ascertain that his product is in compliance with all applicable motor vehicle safety standards and regulations. While your test methods appear to be reasonable, the agency will test seats in the vehicle rather than on a surrogate test frame. You must exercise due care to assure that your simulated test is a true determination whether the seats would comply with the standard when tested as provided in that standard. (The vehicle manufacturer is, of course, responsible for compliance with Standard 207.); Regarding your second question, the pedestal base would be considere part of the seat assembly for purposes of Standard 207. This means that the agency would test the entire assembly by applying a force of 20 times the combined weight of the seat and the pedestal, contrary to your simulated test procedure of using only the weight of the seat frame and adjuster, without the pedestal base attached.; Finally, the force requirements of Safety Standard No. 210, *Seat Bel Assembly Anchorages*, (5,000 pounds) are applied simultaneously with the force requirements in Standard No. 207, if the anchorages are connected to the vehicle seat, to the pedestal, or to the pedestal base.; Please contact this office if you have any further questions, an please excuse the delay in this response.; Sincerely, Joseph J. Levin, Jr., Chief Counsel