Interpretation ID: nht68-4.7

DATE: 09/02/68

FROM: AUTHOR UNAVAILABLE; C. D. Ferguson; NHTSA

TO: General Supply and Equipment Company, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of August 7, 1969, to the Federal Highway Administration, concerning head restraints on your 1969 Lincoln Continental Sedan.

Federal Motor Vehicle Safety Standard No. 202: Head Restraints Passenger Cars, specifies that a head restraint must be provided at each outboard front seating position on cars manufactured on or after January 1, 1969. This standard does not prohibit an individual from modifying or removing the head restraints once he purchases the car. However, a particular state may have inspection laws which prohibit such actions. I suggest you check the matter with your state inspection authorities.

Our Highway Safety Program Standards, copy enclosed, set minimum performance requirements for state inspection programs. Each state is free to establish its own program which meets or exceeds the Federal guidelines. The fact that our Federal Motor Vehicle Safety Standard requires head restraints to be installed on all new passenger cars is evidence of our belief in the level of safety provided by these devices in rear collisions. We would strongly endorse a state inspection program which supported this and our other standards. I am enclosing a booklet which describes all of our motor vehicle standards.

Regarding your particular case, we agree that good visibility is necessary for the safe operation of an automobile. However, properly designed head restraints should not significantly restrict visibility. The injury-reducing benefit far outweights the slight loss of visibility which may occur in certain passenger cars. See(Illegible Word) to the head restraint standard enclosed.

As a practical matter, I would not recommend removal of your head restricts. Aside from the level of rear collision protestion which they provide, their removal may mean that their support structure within the seat back is exposed and this may present a hazard to any rear seat occupants who may hit their heads on the front seat back in a forward collision.

I would suggests the alternative of an additional rear view mirror on the right side of your vehicle to provide increased rear visibility.

Your interest in our progress is appreciated.