Interpretation ID: nht80-1.46

DATE: 04/04/80

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: American Motors Corporation

TITLE: FMVSR INTERPRETATION

TEXT: This responds to your letter of January 14, 1980, requesting an interpretation concerning the proper designated seating capacity for the front seats of the 1981-model AMC Concord. Your letter states that the Concord front seats have over 50 inches of hip room as measured by SAE procedure J1100a, but you characterize the seats as "individual" seats since they are separately adjustable. You ask whether the seats can qualify as having only two designated seating positions.

Based upon the information in your letter and on the photographs you submitted February 22, it is our opinion that there must be three front designated seating positions in the 1981 AMC Concord. The amended definition of "designated seating position" provides that there shall be at least three positions in any bench or split-bench seat having greater than 50 inches of hip room, unless there is some obstruction or design preventing use of the center position. Although the seats in this model are on separate tracks and are separately adjustable, they are the functional equivalent of a split bench seat when the two sections are side-by-side (as illustrated in your Number One photograph). There is not sufficient space between the seats for them to qualify as separate bucket seats. Bucket seats are typically separated by at least 8 to 10 inches. The juxtaposition and design of these "individual" seats creates a well-padded center position. Further, although the inboard buckle portion of the seat belt assemblies occupy the center position, the buckles can be easily pushed down between the seats and would not be an impediment to use of the center position (as illustrated in your photograph Number Three).

For these "individual" seats to qualify as having only two designated seating positions, it is our opinion that they would have to be much further apart, as is true of typical bucket seats, since they currently provide over 50 inches of hip room. Alternatively, the buckle ends of the seat belt assemblies would have to be on much stiffer cables that could not be moved out of the way or pushed between the seats. Moreover, these buckle ends must extend far enough onto the seat to provide true obstructions to use of the center position.

Finally, I would emphasize that this letter only represents the agency's opinion based on the information supplied in your submissions. The NHTSA does not pass approval on any vehicle design, for any safety standards, prior to the actual events that underlie certification. It is up to the manufacturer to determine whether its vehicles comply with all applicable safety standards and regulations, and to certify its vehicles in accordance with that determination.

SINCERELY,

American Motors Corporation

January 14, 1980

Joan B. Claybrook, Administrator National Highway Traffic Safety Administration U.S. Department of Transportation

Dear Ms. Claybrook:

This letter is written to solicit your concurrence with our planned two-passenger seating designation for the front "individual" seats installed in our 1981 model AMC Concord. Since its introduction, this particular vehicle and seat configuration has been assigned a two-passenger designation. We believe that this designation has been and continues to be consistent with our customer's perception of "likely use" for this specific seating package.

We base this opinion on the unique design characteristics of our "individual" seats. Each seat is separately adjustable so that each occupant can select a comfortable amount of leg room. In addition, each seat is equipped with a seat back recliner mechanism allowing each occupant to select and vary the seat back angle to their personal preference.

Incremental to these separate and unique adjustment characteristics, the seat itself is specifically styled and contoured to convey the impression of two-passenger capacity. The design philosophy is to provide the customer with the convenience of "bucket" seats in a less sporty, more luxurious interior package.

The perception of two-passenger capacity is carried through in the design of the seat belt restraint system. The inboard belts are equipped with stiff webbing guides to help locate the buckle ends. These two inboard buckle stalks are a clear indication that each seat is intended to be used by only one person at a time.

The concern over our intended designation for this vehicle/seat configuration rests with the singular criterion of hip space. As measured by the procedures of SAEJ-1100a, the AMC Concord has over 50 inches of hip space. Nevertheless, the above noted design and functional characteristics of our "individual" seats, as well as the distinct separation of these seats in the vehicle, preclude their "likely use" by more than two passengers.

We ask for your concurrence with our two-passenger designation by March 1, 1980.

W. C. Jones Director - Vehicle Safety Programs

February 21, 1980

R. E. Nelson National Highway Traffic Safety Administration

Reference: MRM-12

Dear Mr. Nelson:

Enclosed per your request are pictures of our planned 1981 AMC Concord front "individual" seats. These are being submitted as supplemental information in support to our January 14, 1980 request for the NHTSA's concurrence with our two-passenger seating designation for this specific seating package.

Photograph number one illustrates the styling philosophy of two distinctly separate and contoured seats which are packaged with a restraint system that includes stiff webbing stalks to prominently locate the inboard buckle ends. Also demonstrated are the unique functional characteristics of the these seats which include a separately adjustable seat back (photograph number two) in addition to the normal individual fore-aft adjustment provision (photograph number three).

These pictures demonstrate why the overall styling, design and function of these individual seats give a clear perception of their two-passenger designation.

W. C. Jones Director - Vehicle Safety Programs

(Graphics omitted)

Number One

(Graphics omitted)

Number Two

(Graphics omitted)

Number Three