Interpretation ID: aiam1469
Rozner and Yorty
Suite 1808
10960 Wilshire Boulevard
Los Angeles
CA 90024;
Dear Mr. Goichman: This responds to your March 26, 1974, request for information on sea belt regulations as they concern reclining passenger seats.; Federal Motor Vehicle Safety Standard No. 208, *Occupant Cras Protection,* requires passenger cars to be equipped with seat belt assemblies, but it does not contain performance requirements to regulate the effectiveness of the belt assembly with the seating system in the reclining position.; Federal Motor Vehicle Safety Standard No. 207, *Seating Systems* specifies minimum safety requirements for motor vehicle seats. The requirements of the standard are based on conventional seat designs that normally incorporate a seat back angle of approximately 25 degrees rearward inclination from the vertical. Standard No. 207 requires that reclining seats be tested in their most upright position and does not require seats to be tested in the reclining position.; The National Traffic and Motor Vehicle Safety Act of 1966 preempt state motor vehicle safety regulations which are not identical to the Federal standards with regard to the same aspect of performance and therefore any state law would be identical to Standards Nos. 207 and 208 on these aspects of performance (15 U.S.C. S1392 (d)).; The engineering staff is not aware of any studies in the area of sea belts and reclining seats.; Yours truly, Richard B. Dyson, Assistant Chief Counsel