Interpretation ID: nht79-3.36
DATE: 03/06/79
FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA
TO: Lifetime Foam Products, Inc.
TITLE: FMVSS INTERPRETATION
TEXT: This is in response to your letter of February 8, 1979, requesting confirmation of your understanding of an October 7, 1976, letter of interpretation by our office concerning Safety Standard No. 207, Seating Systems. You are correct in your assumption that the standard applies only to completed vehicles and not to vehicle seats as individual equipment.
SINCERELY,
LIFETIME Foam Products, Inc.
February 8, 1979
Office of the Chief Counsel National Highway Traffic Safety Administration U. S. DEPARTMENT OF TRANSPORTATION
Gentlemen:
Attached is a copy of our inquiry to your office dated September 10, 1976, and the response from your office dated October 7, 1976.
Although we make every effort to build our merchandise to meet the provisions of Standard No. 207, we have understood your response to mean that our seating pieces did not have to meet the provisions of that standard if the pieces are sold to customers who purchase them out of retailer's catalogs to install in their own vehicles.
I would appreciate your confirming our understanding of your response.
Frank Tedesco PRESIDENT
September 10, 1976
Office of the Chief Counsel National Highway Traffic Safety Administration U. S. DEPARTMENT OF TRANSPORTATION
Gentlement:
Cortification of Optional Accossory Seats for Recreational Vehicles and Multipurpose Vehicles per FMVSS207
Lifetime Foam Products is proceeding toward the furbrication of custom, recreational vehicle seating accossories which would be marketed to the public through the catalog division of our parent organisation, Sears, Roobuck and Co. The following list of consumer-installed seating accessories is representative of this new product line.
1. Convertible bad/bench/dinette set.
2. Convertible couch/bed.
3. Tower-back seat.
4. Recliner chair.
Because we are entering a new aspect of our operations, we are most eager that the structural designs meet our high standards of quality as well as applicable operational standards. During the preliminary stages of our activitions, I talked with Mr. Robert Gardner of NHTSA on July 29, and he recommended that I contact your office. Therefore, the purpose of this inquiry is to obtain approval from DOT for certification of these seats according to the applicable sections of FMVSS207 using only "bench tests" (out-of-vehicle) which will certify everthing except the seat-to floor attachment. The reason for excluding the seat-to-floor attachment is that these optional accessory seats will eventually be installated by the consumer in many types of recreational vehicles, in numerous configurations and on floors whose structural integrity cannot be predicted (Illegible Word). These certification tests would be conducted in accordance with NHTSA approval "Laboratory Procedured for Seating Systems: Passenger Cars, Trucks, Buses and Multipurpose Vehicles, TP207-06" or subsequent update of the procedure when they (Illegible Word) available.
As a result of this unknown condition of the floor structure in the user's vehicle, we plan to include in the installation instructions a cautionary statement to the following effect:
"Install per instructions using large area washers furnished in the installation kit. Those washers are to be installed on the underneath side of the floor pan between the attachment not and the vehicle floor. The washers will componsate for an (Illegible Word) 10% reduction in floor strength. In the event that the floor has detolorated beyond this point, it is recommended that the owner contact a qualified shop for assistance."
I would appreciate a reply to this request for approval as soon as possible. If approval is granted, we will then proceed with the certification tests as outlined above.
Frank Tedesco
cc: W. J. ANTLEFORD/SOUTHWEST RESEARCH INSTITUTE; L. C. CODKIN; S. A. WELLER/SEARS, ROEBUCK AND CO.