Interpretation ID: nht92-3.31

DATE: 10/02/92

FROM: MARK W. STEVENS -- CHAIRMAN, SEATMORE

TO: PAUL JACKSON RICE -- CHIEF COUNSEL, NHTSA

ATTACHMT: ATTACHED TO LETTER DATED 11-13-92 FROM PAUL J. RICE TO MARK W. STEVENS (A40; STD. 207; STD. 208; STD. 209; STD. 210; STD. 302; VSA 108

TEXT: We are in the process of designing and manufacturing a after market 3rd rear facing seat for the Ford Taurus and Mercury Sable station wagons 1986-1993.

The Product information contained in these document is proprietary and confidential trade secret information of Seatmore. We ask that this information be kept confidential.

We have asked Johnson Safety in California to manufacture the 3rd seat described in these documents, they have contacted James Gilkey in Code Enforcement Division. Mr. Gilkey suggested that we contact you with the following questions in order to know proper testing requirements.

1. Does the aftermarket 3rd rear facing station wagon system have to be tested in compliance with FMVSS 207, 209, & 210?

2. The seat belt anchorages are Ford factory anchorages built into the car at the factory and designed specifically for the Ford factory 3rd seat and seat belts. We will be using the same anchorages with aftermarket seat belts already in compliance. Is a test required for this system?

3. If testing is required, must they be specifically Static Tested or Dynamic Crash Tested?

I have enclosed pictures with descriptions of the seat and Ford factory mountings for your review.

Please feel free to call if you have questions or need further information. We are ready to take this product to the auto aftermarket and we would appreciate your review and response as soon as possible.