Interpretation ID: nht79-3.2

DATE: 09/28/79

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: L. M. Delgado

TITLE: FMVSS INTERPRETATION

TEXT:

NOA-3O

Mr. Lourdes M. Delgado 3000 Kennedy Boulevard Room 307 Jersey City, New Jersey 07306

Dear Mr. Delgado:

This responds to your recent letter requesting information concerning Federal and State laws applicable to the manufacture of van seats.

The National Highway Traffic Safety Administration issues safety standards and regulations governing the manufacture of motor vehicles and motor vehicle equipment. Safety Standard No. 207, Seating Systems (49 CFR 571.207), specifies performance requirements for seats, their attachment assemblies and their installation to minimize the possibility of seat failure resulting from crash forces. This standard is applicable to seats as installed in vehicles, including vans, but is not applicable to seats as individual pieces of motor vehicle equipment. Therefore, the vehicle manufacturer, not the seat manufacturer, would be responsible for compliance with Standard No. 207. However, under section 151, et seq., of the National Traffic and Motor Vehicle Safety Act, a manufacturer of vehicle seats would be responsible for any safety related defects in his products and would be required to notify owners and remedy the defects.

I am enclosinq a copy of Safety Standard No. 207 for your information, as well as an information sheet that explains where you can obtain copies of all our standards and regulations. You will have to contact the individual States in which you are interested to find out if there are any State or local laws applicable to your business.

Sincerely,

Frank Berndt Chief Counsel

Enclosures

3000 Kennedy Boulevard Room 307 Jersey City, N.J. 07306

August 20, 1979

NHTSA Office of Chief Counsel 400 7th Street, S.W. Washington, D.C. 20590

Gentleman:

I am planning to start my own business, manufacturing van seats. I would appreciate if you can send me federal and state laws and regulations conserning the safety for van seats.

Please mail to:

Lourdes M. Delgado 3000 Kennedy Blvd. Room 307 Jersey City, N.J. 07306

Thank you for your time and cooperation.

Sincerely,

Lourdes M. Delgado

LMD/tr