Interpretation ID: nht72-3.27

DATE: 01/01/72 EST.

FROM: Richard B. Dyson; NHTSA

TO: Brockway Motor Trucks

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of September 12, 1972, regarding the application of S4.3 of Standard No. 207, Seating Systems, to an auxiliary folding seat installed in Brockway trucks.

As shown in your drawings and photographs, the seat faces forward and has a hinge at the rear of the lower cushion. An upward force at the front of the lower cushion will move the cushion upward and rearward until it presses against the seat back.

The intent of S4.3 is to reduce the forces acting on an occupant in an accident by preventing the seat or seat back from folding onto him. It does not appear from the material you have submitted that any motion of the lower seat cushion will impose such additional forces on an occupant. The folding action is therefore not of the type contemplated by the standard and no restaining device would be required for this seat.