Interpretation ID: nht71-5.3

DATE: 11/18/71

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Recreational Vehicle Institute, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: As we have advised Ed Bernett of your office from time to time during the fall, a response to your letter on the treatment of removable foam seat cushions under Standard No. 207 has been under review for some time.

Standard No. 207 is essentially a test of the strength of the seat structure. As such it does not prohibit the use of removable seat cushions of the type described in your letter.

We consider it to be the intent of the standard, however, that when the momentum of a cushion is transferred in any way to the seat structure during the course of an acceleration in a given direction, the weight of the cushion must be added to the weight of the seat structure in calculating the force to be applied in that direction under 84.2 and 34.3.2.