Interpretation ID: nht91-6.39

DATE: October 24, 1991

FROM: Sue Ellen Russell -- Brand & Lowell

TO: Paul Jackson Rice -- Chief Counsel, NHTSA

COPYEE: Robert Hellmuth; Robert Krauss; Harry Thompson; Z Taylor Vinson

TITLE: None

ATTACHMT: Attached to letter dated 1/14/92 from Paul Jackson Rice to Sue Ellen Russell (A39; Std. 207; Std. 210)

TEXT:

This firm represents the Glaval Corporation, a company engaged in the business of van conversions.

Glaval recently notified NHTSA of its intention to conduct a notification and remedy campaign to respond to an apparent noncompliance with the safety belt anchorage strength requirements as they apply to the rear bench set in Glaval vans. These seats contain three designated seating positions, and each seat belt anchorage is mounted on the seat, not the floor.

In the course of evaluating potential remedies to ensure their compliance with the requirements of the standard, we became aware of a recent interpretation of FMVSS 210 (S4.2) issued to R.W. Schreyer of the Transportation Manufacturing Corporation (April 9, 1990). A copy is enclosed for your convenience. In this interpretation, the agency stated that ONLY FLOOR-MOUNTED anchorages common to a single seat and governing "adjacent seating positions" would be tested simultaneously for compliance with FMVSS 210. The letter reiterates that

"Even those anchorages common to one occupant seat would be tested simultaneously only if the anchorages were floor-mounted."

This interpretation raises several questions, because the Glaval bench seat in NHTSA's test was subjected to simultaneous loading of the anchorages for all three seating positions, although none of these anchorages is floor-mounted. Glaval's testing, conducted in accordance with the published test procedures in order to replicate the NHTSA test, also loaded the three seating positions simultaneously.

Glaval's questions are:

1. Consistent with the Schreyer interpretation, should the seat-mounted anchorages of the Glaval bench seat have been loaded sequentially in NHTSA's test? If so, how does NHTSA's test on the Glaval bench seat, where the loads were applied simultaneously, affect NHTSA's tentative conclusion of noncompliance?

2. Since Standard 207 requires simultaneous loading of the forces required by Standard 207 along with those required by Standard 210, does the Schreyer interpretation mean that, for a bench seat with seat-mounted anchorages, the proper loading for a

test pursuant to FMVSS 207 should be 20 times the seat weight, plus the proper load for one designated seating position on the bench seat?

We look forward to Your early response to these questions, as they will affect Glaval's on going work on this issue.

Attachment

Letter dated 3/5/90 from R.W. Schreyer, of Transportation Manufacturing Corporation to Harry Thompson, of NHTSA. (Text omitted)