Interpretation ID: nht93-6.16

DATE: August 17, 1993

FROM: Erika Z. Jones -- Mayer, Brown & Platt

TO: John Womack -- Acting Chief Counsel, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 10/7/93 from John Womack to Erika Z. Jones (A41; Std. 213)

TEXT:

I am writing to confirm our interpretation of FMVSS 213, S5.2.3.2, regarding the covering required on a surface that can be contactable by a child's head.

That provision requires that a contactable surface be covered by material with a specified compression deflection and a minimum thickness of 3/4 inch for materials having a 25 percent compression-deflection resistance of less than 1.8 psi.

As I understand this provision, the required covering material need not be provided in a single piece, as long as the material taken together would satisfy the compression deflection and minimum thickness requirements. Specifically, we understand that the requirement could be met by providing energy absorbing material in two pieces -- one piece bonded to the seat shell and one piece contained within the back of the permanently attached seat cushion, if the combined thickness of the two pieces is at least 3/4 of an inch.

We appreciate knowing whether you concur with this understanding of the requirements of FMVSS 213. Thank you for your attention to this request.