Interpretation ID: nht90-1.4

TYPE: Interpretation-NHTSA

DATE: 01/01/90 EST

FROM: Stephen W.A. Pickering -- Valley Sales Inc.

TO: Stephen R. Kratzke -- Deputy Assistant Chief Counsel for Rulemaking, NHTSA

TITLE: None

ATTACHMT: Attached to 5 photos (graphics omitted); Also attached to Report on Test of Sofa Bar according to FMVSS No. 210 (text and graphics omitted); Also attached to Test Report Number 096441-89 (text and graphics omitted) (test results are available i n the file); Also attached to letter dated 9-10-90 from P.J. Rice to S. Pickering (A36; Std. 111, Std. 202, Std. 207; Std. 208; Std. 209; Std. 210)

TEXT:

Per our conversation by telephone please find enclosed photographs, drawings, descriptions, and accompanying data that I have available at this time concerning the product I am making, trade named "RUMBLE SEAT". The product is a rear facing auxilary seat ing system for Pick up trucks.

It is a unique product that I have initiated a patent application on and a product which I have designed to be as safe and comfortable as I can.

It is my wish to be in compliance with any applicable codes and standards that I am now aware of or those I become aware of at a later date.

I have used for reference the Code of Federal Regulations (CFR) Title 49 containing National Highway Traffic Safety Administration (NHTSA) Standards.

I have listed those standards that I feel may apply to my product, and those I feel I am in compliance with, Or at least those I feel I am NOT out of compliance with.

CODE 49-Standard 209 "Seat belt Assemblies"

I believe I am in compliance by the "DEFINITIONS" S3 by using a Type 1 seatbelt assembly a "LAP BELT FOR PELVIC RESTRAINT" please see enclosed test data on the seatbelts I am now using.

CODE 49 Standard 210 "Seatbelt Assembly Anchorages"

I have enclosed pictures, drawings, and test result data for you to determine compliance, I feel I comply here also.

CODE 49 Standard 571.208 "Occupant Crash Protection"

S4.1.1.3.2. "Convertibles and open body type vehicles" provides that either Type 1 or Type 2 seatbelt assemblys may be used. I am using a Type 1 belt assembly Manual Seatbelts, again, please find test data.

CODE 49 Standard S571.111 "REARVIEW MIRRORS"

My product provides seating for 2 (two) people with space between each

seat to help minimize interference with drivers "FIELD OF VIEW" When the seats are un-occupied with the headrests down there is very minimal interference with view and does not compromise, my compliance status at all.

CODE 49 Standard 571.202 "HEAD RESTRAINTS"

I feel I need HELP with interpertation and compliance here.

Because my product sets directly behind the cab, facing the rear of the pick-up bed, any adult would find the back of the head in close proximity to the outside rear of the cab.

It seemed prudent, therefore, to offer some sort of protection

While there may be several ways to attempt to accomplish this I need to settle on one that will be in compliance with the codes and standards of your bureau.

One way would be a stationary headrest in corporated in the product.

Another may be a stationary headrest permanently affixed to the cab.

Another may be an ADJUSTABLE headrest permanently affixed to the cab.

Another may be a removable headrest either on the product itself, or on the cab. (I WOULD FAVOR THIS SYSTEM)

I decided an adjustable headrest incorporated into the product would be the best way to proceed.

There is one other choice that I have considered, and I am in the opinion that I may have an easier time with compliance. I briefly describe the other system in the enclosed explaination and drawing.

I am asking you to comment as to the possibility of compliance of each system described I have outlined here.

Thank you for your consideration and I hope to be in contact with you regarding my progress in complying with any applicable standards. ANY additional suggestions you may have would be helpfull.

enclosed:

1. test results of seatbelt systems from United States Testing Co. 2. Test results for seatbelt bar anchorage system from Stoutco. 3. Photographs and drawings of product seeking compliance. 4. Possible alternate headrest mounting systems. explaination a nd drawings.

(Photos and text are omitted but are available in the file.)