nht76-5.25 | NHTSA

DATE: 11/22/76

FROM: AUTHOR UNAVAILABLE; Frank A. Berndt; NHTSA

TO: Kustom Fit of Ohio Inc.

TITLE: FMVSR INTERPRETATION

TEXT: This responds to your April 30, 1976 request for confirmation that "liability" for the correct location of a vehicle's seating reference point (SRP) lies with a vehicle manufacturer or alterer that installs seating and not with the manufacturer of the seat. I regret that we have not responded to your request sooner.

"Seating reference point" is defined by NHTSA regulations (49 CFR @ 571.3) to mean --

. . . . the manufacturer's design reference point which --

(a) Establishes the rearmost normal design driving or riding position of each designated seating position in a vehicle;

(b) Has coordinates established relative to the designed vehicle structure;

(d) Is the reference point employed to position the two dimensional templates described in SAE recommended Practice J826, "Manikins for Use in Defining Vehicle Seating Accommodation", November 1962.

While the term "manufacturer" found in the beginning of this definition could refer to either a vehicle or equipment manufacturer under the relevant statutory definition (15 U.S.C. & 102(5)), the references in subparagraphs (a) and (b) make clear that the SRP is a location established with reference to the vehicle structure. It is a commonly understood reference point for specifying the available space for a seated occupant within a vehicle. The only exception to this relationship to the vehicle has been in the case of Standard No. 222, School Bus Passenger Seating and Crash Protection, where the NHTSA has indicated it would accept an SRP designation that is established with reference to the seat frame. This policy is limited to school buses where seat placement within the vehicle is subject to more variation than in other vehicle types.

This means that the NHTSA, in verifying the compliance of a vehicle with a standard such as Standard No. 210, Seat Belt Anchorages, will ask the vehicle manufacturer for the location of the SRP.

SINCERELY,

KUSTOM FIT of OHIO Inc.

April 30, 1976

National Highway Traffic Safety Administration On August 6, 1975 the Recreational Vehicle Industry Association issued bulletin #MS32-752 to all manufacturers and suppliers which dealt with seating reference points in M.P.V.'s.

This letter enclosed please find a copy of it, has created a misunderstanding of responsibilities between the seating manufacturer and the Original Equipment Manufacturer or converters of recreational vehicle products.

It has been the accepted responsibility of the seating manufacturer to establish compliance with standard No. 207 which has to do with pull testing, the integrity of the seat, etc. Our product has been tested extensively by independent laboratories and is regularly pull tested within our own plant to establish that we maintain these standards. The SRP point however is established by fitting a special mannequin into the vehicle in such a manner that its feet are in contact with the gas pedal and floor while its other various extremities are in contact with the steering wheel, etc. By using this method the outboard designated seating position is established in each vehicle as well as the head impact area and the pelvic impact area and the torso line. The only possible way to establish that seating reference point is to check a seat as it is installed in the vehicle complete with its seat belt anchoring system. This SRP point would vary with every model in which it is installed.

Kustom Fit manufactures seats for installation in a wide variety of vehicles and deals with over five hundred customers. While we can give the center of gravity of the seat from which its original pull test were made and are happy to do so we are not in a position to supply the SRP point which is the responsibility in our opinion of the vehicle manufacturer or converter rather than a seat manufacturer.

This being the case we ask that you supply us and the R.V.I.A. with a letter stating that the liability for the correct SRP point lies with the converter of the vehicle or manufacturer rather than with a component manufacturer such as ourselves.

We thank you for your help.

James A. Rupp Vice President General Manager

cc: EARL BELK; JIM PORTER; R.V.I.A. (Illegible Text) (Illegible Text) (Illegible Text) (Illegible Text)

Interpretation ID: nht76-5.25