Interpretation ID: nht72-4.10

DATE: 11/09/72

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Renault, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of October 16, 1972, concerning the seat adjustment procedures of S8.1.2 of Motor Vehicle Safety Standard No. 208.

As described in your letter, some models manufactured by Renault have front seats that can be adjusted to an extreme forward position to allow the reclining seat back to be fully lowered. You imply that this position cannot be used for driving the vehicle, and ask whether the "forwardmost" position referred to in S8.1.2 could be interpreted to be the forwardmost driving position.

The purpose of S8.1.2 is to specify an adjustment position that is appropriate for the 50th percentile adult male occupant used in the standard's barrier tests. If the adjustment range is determined by using the extreme forward position you describe, the midway point would no longer be appropriate for the 50th percentile adult male size. It is therefore consistent with the purpose of S8.1.2 to exclude the extreme, non-driving positions in determining the midway adjustment position.

However, despite the references in some parts of the standard to an occupant of the 5th percentile adult female size, the adjustment range specified in S8.1.2 does not refer to this or any other size of occupant and we are of the opinion that no occupant size specification can be read into the section.

We would consider a position to be outside the range used to determine the midway point of S8.1.2 if it cannot reasonably be used for driving and if it is separated from other positions by a distance greater than the normal distance between positions. It would appear that the position described in your letter meets these criteria and that it should therefore be excluded in determining the midway position under S8.1.2.