Interpretation ID: aiam2375
Staff
Safety
Nissan Motor Co.
Ltd.
P.O. Box 1606
560 Sylvan Avenue
Englewood Cliffs
NJ 07632;
Dear Mr. Iinuma: This responds to Nissan Motor Company's June 2, 1976, question whethe a passenger car rear seat cushion assembly which is hinged to rotate forward about its lower front corner is subject to the requirement of S4.3 of Standard No. 207, *Seating Systems,* for a self-locking restraining device with certain dynamic characteristics. If a restraining device is required, you request to know the test procedures appropriate for it under S4.3.2.1(a).; Section S4.3 of Standard No. 207 states, with two exceptions, 'a hinge or folding occupant seat or occupant seat back shall be equipped with a self-locking device for restraining the hinged or folding device.' The NHTSA does not consider the words 'occupant seat or occupant seat back' to refer to the seat cushion alone, and therefore a restraining device for the cushion alone is not required. The requirement of S4.2(a) in the case of seating systems with separate backs and cushions is considered a sufficient test of the seat cushion retention characteristics. In the case of the seat cushion assembly you describe, our estimate of the cushion center of gravity in relation to the hinge point indicates that some form of restraint is probably necessary to comply with the requirement for application of a 20g force in the forward direction.; This interpretation supersedes our November 27, 1972, letter to th Recreational Vehicle Institute to the degree that its discussion of seat cushion restraint is inconsistent with this interpretation.; Yours truly, Frank Berndt, Acting Chief Counsel