Interpretation ID: nht80-2.36

DATE: 05/08/80

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Nissan Motor Co. Ltd.

TITLE: FMVSR INTERPRETATION

TEXT: This responds to your recent letter requesting an interpretation concerning folding jump seats you intend to install in some future van models that your company manufacturers. You ask whether the seats would qualify as "designated seating positions", for purposes of the Federal motor vehicle safety standards.

The term "designated seating position" is defined in 49 CFR Part 571.3 as:

any plan view location capable of accommodating a person at least as large as a 5th percentile adult female, if the overall seat configuration and design is such that the position is likely to be used as a seating position while the vehicle is in motion, except for auxiliary seating accommodations such as temporary or folding jump seats . . . . (emphasis added).

As described and illustrated in your letter, the Nissan seats in question appear to qualify as folding jump seats. Consequently, under the definition above they would not be considered "designated seating positions". Although this is the case, we encourage you to install safety belts for these jump seats as you had previously planned. Likewise, we hope you will ensure that the seats have a crashworthiness performance equivalent to that required by Safety Standard No. 207 (for "designated seating positions") when the jump seats are folded into place for occupant use.

SINCERELY,

NISSAN MOTOR CO., LTD.

ENGINEERING OFFICE OF NORTH AMERICA

April 23, 1980

Frank A. Berndt Chief Counsel National Highway Traffic Safety Administration

Dear Mr. Berndt:

We, Nissan Motor Company, Ltd., would like to take this time to ask you for your interpretation concerning Part 571 Definition "Designated Seating Position."

Our questions can be found on the attached pages. We would like to ask that you treat the attached pages as "Confidential" until it is introduced to the public. Your interpretations will be appreciated very much.

Hisakazu Murakami Technical Representative Safety

ATTACH.

cc: HUGH OATES (NOA-30)