Interpretation ID: nht72-3.34

DATE: 05/03/72

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Volkswagen of American, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of April 10, 1972, on the subject of the label required by Standard 207 to be affixed to a seat that is not intended for use while the vehicle is in motion.

Although S4.4 of Standard 207 does not require the warning to be verbal, it is our impression that the concept is difficult to convey by nonverbal symbols. A quick review of personnel in the NHTSA revealed that most of them were familiar enough with the international sign system to know that something was being forbidden, but were unsure as to what the forbidden act was. Of the two symbols, the one showing the vehicle in motion appeared to be more understandable, but not by much.

It is our conclusion that neither of the symbols is adequate to give the warning intended by S4.4. This is not to say that the symbols would not be adequate in other countries whose citizens are more familiar with symbolic labeling. I might add that the label need not contain the exact words of the standard. It would be acceptable, for example, to say "Do not ride in this seat," if you find that shortening the phrase would make the label less cumbersome.