Interpretation ID: aiam0833
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Inc.
10972 Chicago Drive
Zeeland
MI 49464;
Dear Mr. Graham: This is in reply to your letter of August 25, 1972, concerning th application of section S4.3 of Motor Vehicle Safety Standard No. 207 to a folding dinette seat manufactured by your company for use in recreational vehicles.; The seat you describe has a back that folds flat to make a bed. A sea back that travels through such a large arc does not fall within the limited exceptions provided in S4.3 for a 'back that is adjustable only for the comfort of its occupants,' and it must therefore be equipped with a restraining device conforming to S4.3. The quoted language applies to the type of seat whose back is adjustable through a few degrees of arc to provide a variety of riding positions for persons of different sizes and postures. A seat back that folds to the point where it no longer restrains the longitudinal motion of the occupant is required to have a device that prevents it from assuming that position accidentally.; Sincerely, Richard B. Dyson, Assistant Chief Counsel