Interpretation ID: 2865o
12814 Asbury Drive
Ft. Washington, MD 20744
Dear Mr. Madison:
This responds to your March 31, 1988, letter asking for our interpretation of Safety Standard No. 207, Seating Systems, as it applies to a seat installed in a multipurpose passenger vehicle and equipped with a safety belt. You attached a sketch of your seat and asked whether the safety belt assembly is considered to be attached to the seat. You asked this question in order to determine whether the seat would be subject to the specified forces of paragraph S4.2(c) of the standard. The answer is that NHTSA considers the assembly to be attached to the seat.
By way of background information, the National Highway Traffic Safety Administration (NHTSA) does not grant approval of motor vehicles or motor vehicle equipment. Under the National Traffic and Motor Vehicle Safety Act, it is the responsibility of the manufacturer to ensure that its vehicles or equipment comply with applicable requirements. The following represents our opinion based on our understanding of the facts provided in your letter. In this regard, I want to note that rendering an opinion in this case was complicated by the fact that your sketch does not show the seat structure and its interrelationship with the vehicle structure and belt anchorage.
In your letter, you refer to a vehicle having a "Belt Attachment Frame" made from steel members attached to the vehicle's structure. You said that,
"(r)esting on the Belt Attachment Frame is a plywood deck... The seat cushion rests on but is not otherwise attached to the deck. The seat belt attachments pass through the deck and are secured to the Belt Attachment Frame. Other portions of the seat or its supporting structure might rest on and contact the Belt Attachment Frame and might extend to or beyond it. However, except for the deck, no part of the seat or its structural members would be attached to the Belt Attachment Frame." (Emphasis added.)
The answer to your question depends on whether the Belt Attachment Frame is considered part of the seat. Based on the information you provide, we conclude that the Belt Attachment Frame is part of the seat itself. According to your letter, the deck for the seat cushion is attached to and supported by the Belt Attachment Frame; it appears that the Belt Attachment Frame is a necessary and functional part of the seat structure. Since we interpret the Belt Attachment Frame to be a part of the seat, and since the seat belt assembly loads will be transferred to the Frame in the event of a crash, we consider the seat belt assembly to be attached to the seat, for purposes of testing the seat under S4.2(c) of Standard No. 207.
Please contact my office if you have further questions.
Sincerely,
Erika Z. Jones Chief Counsel
ref:207 d:6/30/88