Interpretation ID: 1984-3.17

TYPE: INTERPRETATION-NHTSA

DATE: 08/31/84

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Homer S. Meyers -- President, Easco, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your letter of August 2, 1984, requesting information on which of the agency's regulations would apply to a new product you are considering. You described the product as a cross-bed seat for use in pickup trucks. The seat would be made of plastic and be mounted in the front of the truck bed facing the rear. The following discussion explains the application of our regulations to your potential product.

Since your potential product would be used as a seating position in a motor vehicle while the vehicle is in motion, each occupant position on the seat would be considered a designated seating position by the agency. If your product is installed as an item of original equipment on a truck before its sale to its first purchaser, the designated seating positions must conform to the requirements of Standard No. 207, Seating Systems; Standard No.208, Occupant Crash Protection; Standard No. 209, Seat Belt Assemblies; and Standard No. 210, Seat Belt Assembly Anchorages. I have enclosed an information sheet explaining how you can obtain copies of our safety standards.

If your product is sold as an item of aftermarket equipment to be installed by a vehicle owner, it would not be required to comply with Standards Nos. 207, 208, 209, and 210. However, we strongly recommend that you provide properly-anchored seat belts at each seating position.

Finally, as a manufacturer of an item of motor vehicle equipment, you have a responsibility under section 151 et seq. of the National Traffic and Motor Vehicle Safety Act to conduct a notification and remedy campaign if you or the agency determines that your product contains a safety-related defect or does not comply with an applicable standard. A copy of the Act is enclosed.

If you have any further questions, please let me know.

August 2, 1984

Chief Counsel National Highway Traffic Safety Administration

Gentlemen:

This company is engaged in the business of manufacturing and marketing pick-up truck accessories.

A potential new product which we are considering is a cross-bed seat for such trucks. A sketch is enclosed. This seat would be formed from plastic sheet of sufficient thickness to provide the necessary strength. It would be mounted in the front of the truck bed facing to the rear. It would be supported by the flange around the top, resting on the lip at the front and sides of the bed, and also by an aluminum leg in the middle of the front edge of the seat.

The seat would be held in place by sheet metal screws going into the lip of the bed. Slots would be cut in the rear of the seat to allow passage of seat belts to fastenings on the floor or front wall of the bed. Alternatively, the belts might be fastened to the seat itself with appropriate back-up strengthening plates.

I would apprediate having your opinion as to the safety standard regulations that would apply to such product.

Homer S. Myers

President

EASCO, Inc.

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