Interpretation ID: nht92-1.40

DATE: 12/07/92

FROM: WILLIAM R. WILLEN -- MANAGING COUNSEL, PRODUCT LEGAL GROUP, AMERICAN HONDA MOTOR CO., INC.

TO: PAUL JACKSON RICE -- CHIEF COUNSEL, NHTSA

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 2-24-93 FROM JOHN WOMACV TO WILLIAM R. WILLEN (A40; PART 571.3)

TEXT: This is to request your confirmation of our interpretation regarding the definition of "designated seating position" in 49 CFR Section 571.3 as it applies to a proposed Honda design. The Honda design is similar to one for which NHTSA provided an interpretation to Jguar Rover Triumph in July, 1980. The hip room is 44.2 inches over the length of our seat, and the seat width is only 39 inches. The seat is flat and does not have stiff inboard seat belt receptacles. (Please see the attached sketches).

We believe that, under the above mentioned definition, two designated seating positions would be required for this design and we would like to receive your confirmation. We also reguest your answers to the following questions regarding the determination of designated seating positions.

1. With regard to this proposed design, is the seat width dimension the key factor in determining the number of designated seating positions? If the seat width was 40 or 42 or 44 inches instead of 39 inches would your interpretation be different?

2. Please explain how you would measure hip room in the examples shown below where the seat is installed in a wider vehicle.

(a) The seat is located close to one side with space for passenger access on the other side.

(GRAPHICS OMITTED)

(b) The seat is located in the middle of the vehicle with space on each side.

(GRAPHICS OMITTED)

(c) Note that the seat does not have armrests in the sketches. Would the answer be different if armrests were provided? Would it also make a difference if the armrests were fixed or if they were able to swing up beside the seatback to provide easy access?