Interpretation ID: nht87-2.30

TYPE: INTERPRETATION-NHTSA

DATE: 07/01/87

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: R. O. Sornson -- Director, Regulatory Research and Analysis, Chrysler Corp.

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. R.O. Sornson Director Regulatory Research and Analysis Chrysler Corporation P.O. Box 1919 Detroit, MI 48288

Thank you for your letter requesting an interpretation of the test procedure used in the latchplate access test of Standard No. 208, Occupant Crash Protection. I regret the delay in our response.

You specifically asked for an interpretation of the requirement of S10.6 of the standard that a vehicle's seat shall be placed "in its forwardmost adjustment position" when determining whether a vehicle meets the latchplate reach requirements of S7.4.4 o f the standard. You asked whether in conducting the test, Chrysler should move a manually adjusted bench or bucket seat to its forward seat track "stop" and move a power bench or bucket seat to its "full forward" and "full down" position. As explained be low, both a manually adjusted seat and a power adjusted seat should be moved to its full forward position or full forward seat track stop. However, S7.4.4 of the standard does not currently address how the seat is to be vertically adjusted. The agency ha s recently received a petition from the Motor Vehicle Manufacturers Association asking the agency to address the general issue of positioning adjustable power seats for the purposes of Standard No. 208. If the petition is granted, we will address the iss ue of vertical placement of the seat for the purposes of S7.4.4. In the interim, the agency will conduct its compliance testing for S7.4.4 in the following manner. The agency will first place the seat in the vertical adjustment position used by the manuf acturer in its certification tests. Then the agency will move the seat horizontally to its full forward position.

You noted that several of the comfort and convenience requirements of the standard specifically provide that a seat is to be moved to its full forward and full down position. For example, S7.4.3, which sets out the belt contact force requirements, and S7 .4.5, which sets out the safety belt retraction requirements, specifically provide that the seat is to be tested under the conditions of S8.1.2 of the standard. In turn, S8.1.2 provides that adjustable seats that are capable of vertical adjustment are to be placed in their lowest position.

However, the latchplate access requirement of S7.4.4 of the standard does not have a reference to positioning a seat in accordance with S8.1.2 of the standard. Instead, it specifies only that the seat shall be placed in its full forward adjustment positi on. Thus, in determining a seat's full forward position for the purposes of S7.4.4, the agency will follow the following procedure. Since the standard does not prescribe a vertical position for the seat, the agency will use the vertical position used by the manufacturer in its certification tests. The agency will then move a power seat horizontally to its full forward position.

If you have any further questions, please let me know.

Sincerely,

Erika Z. Jones Chief Counsel

Ms. Erika Z. Jones, Chief Counsel National Department of Transportation National Highway Traffic Safety Administration 400 Seventh Street, S.W. Washington, D.C. 20590

Dear Ms. Jones:

Chrysler Corporation requests confirmation of our interpretation of the requirements of paragraph S10.6 of MVSS 208, Occupant Crash Protection. Paragraph S10.6 prescribes that the seat shall be "in its forwardmost adjustment position" when determining th e seat belt latchplate reach envelopes. Based on our review of Standard 208, we interpret "forwardmost adjustment position" to mean that a manually adjustable bench or bucket seat is moved to the forward seat track "stop" and in similar manner a power be nch or bucket seat is moved to its "full forward" position while in the "full down" position. These adjustment procedures provide a consistent test dummy location which we believe is the NHTSA's intent for conducting the prescribed tests for both manual and power seats.

The above interpretation of "forwardmost adjustment" position was discussed with Mr. Edward Jettner of the Office of Vehicle Standards. He concurred with our interpretation, but suggested that we seek confirmation of it.

We believe that the above interpretation is correct based on other discussions of seat adjustment in the standards. Paragraph S7.4.3 of MVSS 208 provides:

S7.4.3, Belt Contact Force, is tested in accordance with S10.7 which, in turn, requires that the user "--position the test dummy in the vehicle in accordance with -- S10.1 or S10.2 and -- S8.1.2 and S8.1.3." S8.1.2 requires that "adjustable seats are -- midway between forwardmost and rearmost positions, and if separately adjustable in a vertical direction, are at the lowest position; (underlined for emphasis)

Paragraph S.7.4.5 adds:

S7.4.5, Retraction, is also "tested under the conditions of S8.1.2 --."

Paragraph S4.3.2 of MVSS 210, Seat Belt Assembly Anchorages, similarly provides at a power seat is to be adjusted to full down position:

S4.3.2 Seat belt anchorages for the upper torso portion of Type 2 seat belt assemblies. With the seat in its full rearward and downward position . . . . (underlined for emphasis).

From these references, we conclude that for consistency in positioning the test dummy for purposes of paragraph S10.6 of MVSS 208, a power seat is adjusted to the forwardmost "full downward" position and a manual seat track is adjusted to the forwardmost position. We would appreciate your confirmation of our interpretation at the earliest possible date.

Sincerely,

R.O. Sornson