Interpretation ID: nht76-4.43

DATE: 09/02/76

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Nissan Motor Co., Ltd.

TITLE: FMVSS INTERPRETATION

TEXT: This responds to Nissan Motor Company's June 2, 1976, question whether 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 hinged 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 the Recreational Vehicle Institute to the degree that its discussion of seat cushion restraint is inconsistent with this interpretation.

YOURS TRULY,

NISSAN MOTOR CO. LTD.

June 2, 1976

Frank A. Berndt Acting Chief Counsel National Highway Traffic Safety Administration

We would like to take this opportunity to ask you for your interpretation regarding the application of S.4.3 in FMVSS 207 "Seating Systems".

1) Is S.4.3 applied to the hinged seat cushion which is shown in the attachment No. 1? In other words, should the hinged seat cushion be equipped with a self-locking device for restraining itself and a control for releasing that restraining device? Should its restraining device meet the requirements of static force and acceleration stated in S.4.3.2.1 (a) and S.4.3.2.2 respectively?

2) If the answer of the above question is yes, in which direction of (X) or (Z) described in the attachment No. 2 should the restraining device be subjected to an acceleration of 20 g when tested in accordance with S.4.3.2.2?

Thank you for your attention to this matter. We look forward to hearing your interpretation of the above in the near future.

Tokio Iinuma Staff, Safety

CC: ROBERT E. NELSON

Condition of using seat

Condition of folding seat

Attachment No. 1 - the hinged seat cushion installed for the rear seating system of station wagon

(Graphics omitted)

(Graphics omitted)