Interpretation ID: nht80-1.47

DATE: 04/09/80

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Renault USA

TITLE: FMVSR INTERPRETATION

TEXT: This responds to your letter of March 3, 1980, requesting an interpretation concerning the proper designated seating capacity for the rear seat in the Renault Le Car vehicle. You state that the rear seat of the Le Car has 48.2 inches of hip room, and ask whether the vehicle would qualify as having only two designated seating positions.

I am enclosing a copy of a letter of interpretation the agency recently issued to Toyota Motor Company regarding the designated seating capacity of the rear seats in several of its models. The rear-seat designs of these Toyota models are very similar to the Le Car, in that the presence of wheel wells results in hip room measurements below 50 inches under the strict measurement technique specified in the definition of "designated seating position" (SAE J1100a). As was pointed out in that letter, however, if occupants move their hips slightly forward of the wheel wells, which extend only a few inches out into the seat, there is over 50 inches of usable hip room in these vehicles.

Your letter states that the close proximity of the two inboard portions of the rear seat belt assemblies in the Le Car indicates that only two positions are intended by the manufacturer. The agency would give more credence to this factor if the inboard portions of the belt assemblies were on stiff, immovable cables (or similar design). With the current design, a person wishing to sit in the center position can easily move the belts out of the way, so the belts are not real impediments to use of the center position.

In answer to your ultimate question, the agency must conclude that the rear seat in the Le Car vehicle could qualify as having only two designated seating positions since the hip room is below 50 inches according to the technical measurement procedure specified in the standard. However, we think this is an extremely close case since there is over 48 inches of hip room even between the wheel wells and greater than 50 inches of hip room if the measurement is made mid-way the seat cushion. Therefore, we strongly urge Renault to modify its seat design or to add a third set of belts in this vehicle model. As noted in the letter to Toyota, if manufacturers do not voluntarily comply with the clear intent of the definition of "designated seating position", the agency may find it necessary to modify the measurement technique that is currently specified.

Sincerely,

ATTACH.

RENAULT USA

ENGINEERING & PLANNING GROUP.

March 3, 1980

Ralph Hitchcock, Chief -- Crashworthiness Division, National Highway Traffic Safety Administration

Dear Mr. Hitchcock:

Renault hereby requests a confirmation of its interpretation of the designated seating position definition contained in 49 CFR @ 571.3 to the effect that it would require two such seating positions in the rear seat of the Renault Le Car vehicle.

You will recall that we brought a 1980 Renault Le Car to NHTSA in December for examination by you and others of your office as well as representatives from Enforcement and Chief Counsel.

The rear seat width of this vehicle, a two-door hatchback with a folding rear seat, is 48.2-inches measured in accordance with SAE J1100(a). This 48.2-inch dimension includes the wheel wells, which protrude slightly into the seating area.

Renault's intention that the rear seat be limited to two designated seating positions is indicated, among other things, by the fact that the short inboard seat belts for the left and right seated passengers are located adjacent to one another.

Sincerely yours,

Francois Louis -- Governmental Affairs