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Interpretation ID: nht93-3.21

DATE: April 26, 1993

FROM: Donald J. Crane -- ARVIN, Calspan Corporation

TO: Mary Versailles -- Office of Chief Counsel, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 6-25-93 from John Womack to Donald J. Crane (A41; Std. 207).

TEXT: Recently, a customer of Calspan Corporation inquired whether or not their vehicle was exempt from the test requirements in S4.3.2.2, Acceleration of Standard No. 207; Seating Systems. This test subjects the restraining device to an acceleration of 20 g., in the longitudinal direction opposite to that in which the seat folds. The seat types exempt from this requirement are a passenger seat in a bus or a seat having a back that is adjustable only for the comfort of its occupant.

A summary of the seat types and vehicle type for Calspan's customer are in the following table.

Front Seat (Drv. & Pass.) Rear Seat (Bench Seat)

Seat Back Angle 24 degrees 26 degrees

Reclining Angle * Forward: 39 degrees 30' +/- 3 degrees No

Rearward: 58 degrees +/- 2 degrees

Sliding Distance 220 mm No

Folding Forward No Split Seat Back folded

Vehicle Type 4-Door Sedan

* 24 degrees + 58 degrees = 82 degrees

With this information, can you please provide a written interpretation of S4.3.2.2 of Standard 207. Also, is this a full-flat seat? What would the interpretation be if the vehicle was a 2-door type?

I thank you for your attention and assistance in this inquiry. Please call me at (716)631-6854 if you have any questions.