Interpretation ID: nht95-1.4

TYPE: INTERPRETATION-NHTSA

DATE: January 3, 1995

FROM: Richard Kreutziger -- Exec. Dir., NYSBDA

TO: Walter Myers -- Counsel Staff, NHTSA

TITLE: None

ATTACHMT: ATTACHED TO 2/13/95 LETTER FROM PHILIP R. RECHT TO RICHARD KREUTLIGER (A43; STD. 217; PART 571.3)

TEXT: I MUCH APPRECIATE YOUR RETURNING MY TELEPHONE CALL THIS DATE.

THE QUESTION AS POSED TO YOU ON THE TELEPHONE RELATING TO THE AMENDED FMVSS 217 PERTAINS DIRECTLY WITH THE PROTRUSION OF THE "FLIP" SEAT THAT IS POSITIONED DIRECTLY TO THE REAR OF THE LEFT SIDE (CENTER) EMERGENCY DOOR.

AS NOTED ON THE FOLLOWING DRAWING - THE BOTTOM OF THE FRAMEWORK OF THE "FLIP" SEAT DOES EXTEND BEYOND THE "DOOR OPENING". THE EXTENSION VARIES UP TO A MAXIMUM OF 3/4 INCH. EVEN WITH THIS "INVASION" OF THE DOOR OPENING THERE IS NO OBSTRUCTION TO THE DOOR LATCH MECHANISM - AND A DIMENSION OF 11.75" OF CLEAR "AISLE" SPACE IS PROVIDED. THIS AISLE SPACE IS CLEAR TO THE LONGITUDINAL BODY CENTER LINE.

THE DIMENSION IS ACQUIRED THRU THE LOCATION OF THE FORWARD SEAT, IN ACTUAL PRODUCTION THE SEAT AT THE FORWARD EDGE OF THE LEFT SIDE (CENTER) EMERGENCY DOOR IS LOCATED MORE FORWARD THAN THAT AS DEPICTED FROM THE FMVSS DRAWING.

AS PER OUR VERBAL CONVERSATION - AND YOUR UNDERSTANDING AT THE TIME OF THAT VERBAL CONVERSATION OF THE "QUESTION" YOU COMMENTED THAT "AS LONG AS THERE WAS 30 CENTIMETERS (11.7 +") THERE SHOULD BE NO SERIOUS PROBLEM OR OBJECTION".

HOPE THE WRITTEN QUESTION IS PRESENTED PROPERLY AND THAT THE FOLLOWING DRAWING IS ACCEPTABLE - THAT I CAN ASSUME TO HEAR FROM YOU WITH WRITTEN CONFIRMATION PROMPTLY.

THANK YOU.