Interpretation ID: aiam0486

David J. Humphreys, Esq., Recreational Vehicle Institute, Inc., Suite 406, 1140 Connecticut Avenue, Washington, DC 20006; David J. Humphreys
Esq.
Recreational Vehicle Institute
Inc.
Suite 406
1140 Connecticut Avenue
Washington
DC 20006;

Dear Mr. Humphreys: As we have advised Ed Bernett of your office from time to time durin the fall, a response to your letter on the treatment of removable foam seat cushions under Standard No. 207 has been under review for some time.; Standard No. 207 is essentially a test of the strength of the sea structure. As such it does not prohibit the use of removable seat cushions of the type described in your letter.; We consider it to be the intent of the standard, however, that when th momentum of a cushion is transferred in any way to the seat structure during the course of an acceleration in a given direction, the weight of the cushion must be added to the weight of the seat structure in calculating the force to be applied in that direction under S4.2 and S4.3.2.; Please advise us if you have further questions. Sincerely, Richard B. Dyson, Assistant Chief Counsel