Interpretation ID: aiam2397
President
Lifetime Foam Products
Inc.
3001 Cullerton Drive
Franklin Park
IL 60131;
Dear Mr. Tedesco: This responds to your September 10, 1076, request for approval from th National Highway Traffic Safety Administration (NHTSA) for certification of 'consumer-installed seating accessories' to Standard No. 207, *Seating Systems*, by means of bench testing.; Standard No. 207 and the statute under which it is authorized (Th National Traffic and Motor Vehicle Safety Act (the Act), 15 U.S.C. S 1381, *et* seq.) do not permit the assistance you request. The Act requires 'self-certification' by manufacturers that their products comply with applicable standards (15 U.S.C. S 1403). The NHTSA does not 'approve' compliance tests for this reason.; Also, Standard No. 207 applies only to vehicles, and most of th requirements of the standard must be conducted with the seating as it is installed in the vehicle. For example, the application of force to the seat in the forward and rearward directions (S4.2) measures the seat's structural strength and its attachment to the vehicle. Your seating systems are subject to these requirements only if they are installed in a vehicle prior to its first sale for purposes other than resale.; While we are unable to provide the 'approval' you requested, we suppor your intention to ensure that the structure of your products conforms to existing requirements for motor vehicle seating as set forth in Standard No. 207. Although it appears that you are familiar with the requirements of Standard No. 207, I have enclosed an information sheet that explains where copies of the motor vehicle safety standards may be obtained.; Sincerely, Frank A. Berndt, Acting Chief Counsel