Interpretation ID: nht72-3.30

DATE: 09/08/72

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Auto Top, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of August 25, 1972, concerning the 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 seat 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.