Interpretation ID: nht71-5.11

DATE: 12/02/71

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Lotus Cars Ltd.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of November 16, 1971, in which you asked whether Standard No. 208 would require seat belt retractors to be installed after January 1, 1972, for the rear occasional seats of the Lotus Plan Plus Two. Our answer is that retractors will be required if the rear seats are "designated seating positions" as defined in our regulations at 49 CFR 571.3(b). The definition provides, among other things, that to be a designated seating position a seat must accomodate a 5th percentile adult female. To define an occupant of this size, the regulations incorporate a U.S. Public Health Service publication that includes the following specifications: weight, 104 pounds; standing height, 59 inches; sitting height, 30.9 inches; knee height, 17.9 inches; buttock-knee length, 20.4 inches. If the Plan Plus Two cannot accomodate a person of this size in the rear seat, it need not have a seat belt retractor for that seat. If such a person can be accomodated, then retractors will be required unless the seat is otherwise exempt by the definition as an auxiliary seating accomodation such as [a temporary or folding jump seat." We do not have the information necessary to judge whether the seat is exempt as an auxiliary seating accomodation.

Please advise us if further explanation is necessary.