Interpretation ID: aiam4341
Director
Regulatory Research and Analysis
Chrysler Corporation
P. O. Box 1919
Detroit
MI 48288;
Dear Mr. Sornson: Thank You for your letter requesting an interpretation of the tes procedure used in the latchplate access test of Standard No. 208, *Occupant Crash Protection*. I regret the delay in our response. You specifically asked for an interpretation of the requirement of S10.6 of the standard that a vehicle's seat shall be placed 'in its forwardmost adjustment position' when determining whether a vehicle meets the latchplate reach requirements of S7.4.4 of the standard. You asked whether in conducting the test, Chrysler should move a manually adjusted bench or bucket seat to its forward seat track 'stop' and move a power bench or bucket seat to its 'full forward' and 'full down' position. As explained below, both a manually adjusted seat and a power adjusted seat should be moved to its full forward position or full forward seat track stop. However, S7.4.4 of the standard does not currently address how the seat is to be vertically adjusted. The agency has recently received a petition from the Motor Vehicle Manufacturers Association asking the agency to address the general issue of positioning adjustable power seats for the purposes of Standard No. 208. If the petition is granted, we will address the issue of vertical placement of the seat for the purposes of S7.4.4. In the interim, the agency will conduct its compliance testing for S7.4.4 in the following manner. The agency will first place the seat in the vertical adjustment position used by the manufacturer in its certification test. Then the agency will move the seat horizontally to its full forward position.; You noted that several of the comfort and convenience requirements o the standard specifically provide that a seat is to be moved to its full forward and full down position. For example S7.4.3, which sets out the belt contact force requirements, and S7.4.5, which sets out the safety belt retraction requirements, specifically provide that the seat is to be tested under the conditions of S8.1.2 of the standard. In turn, S8.1.2 provides that adjustable seats that are capable of vertical adjustment are to be placed in their lowest position.; However, the latchplate access requirements of S7.4.4 of the standar does not have a reference to positioning a seat in accordance with S8.1.2 of the standard. Instead, it specifies only that the seat shall be placed in its full forward adjustment position. Thus, in determining a seat's full forward position for the purposes of S7.4.4, the agency will follow the following procedure. Since the standard does not prescribe a vertical position for the seat, the agency will use the vertical position use by the manufacturer in its certification tests. The agency will then move a power seat horizontally to its full forward position.; If you have any further questions, please let me know. Sincerely, Erika Z. Jones, Chief Counsel