Interpretation ID: nht80-3.42

DATE: 08/29/80

FROM: AUTHOR UNAVAILABLE; Stephen P. Wood for F. Berndt; NHTSA

TO: P. J. O'Connor

TITLE: FMVSS INTERPRETATION

TEXT:

AUG 29 1980 NOA-30

Mr. Patrick J. O'Connor P.O. BOX 905 10 East Court Street Doylestown, Pennsylvania 18901

Dear Mr. O'Connor:

This responds to your letter of July 2, 1980, requesting information regarding manufacturing standards for front bucket seats on passenger cars. Specifically, you ask if there are any standards that were applicable to 1969-model Mustangs, particularly with respect to the pivot pin brackets on seats in these vehicles.

The initial Federal Motor Vehicle Safety Standards were issued in 1967 and became effective January 1, 1968. Included in these initial standards was Standard No. 207, Anchorages of Seats--Passenger Cars (copy enclosed). Standard No. 207 specifies performance requirements in terms of overall seat strength. You will note that there are no requirements for specific components of the seat, however, such as pivot pin brackets. The Federal safety standards are generally specified in terms of performance requirements which allow manufacturers to use any designs they choose. If the Mustang with which you are concerned was manufactured on or after January 1, 1968, the manufacturer would have had to certify that the vehicle was in compliance with all applicable safety standards, including Standard No. 207.

I am also enclosing a copy of Safety Standard No. 207 as it is currently written, since the standard has been amended several times since it was first issued. I hope you will find this information helpful.

Sincerely,

Stephen P. Wood

Frank Berndt Chief Counsel Enclosures

July 2, 1980

David Allen, Esquire Office of Chief Counsel Room 5219 National Highway Traffic Safety Administration 400 7th Street South West Washington, D.C. 20590

RE: Manufacturing Standards-Front Bucket seats

Dear Mr. Allen:

I had written to the Superintendent of Documents in the U.S. Government Printing Office with a request for information concerning the above. On July 2, 1980 I received a phone call from Ms. Mary Chapman, a special Research Technician, advising me that I should write a similar letter of request addressed to you.

In April of 1977 Ford Motor Company initiated a voluntary recall campaign relative to driver's seat, back inboard pivot pin brackets for front bucket seats. The defect existed in 1968 and 1969 Mustangs and Cougars.

I am involved in litigation relative to a 1969 Mustang in which this defect existed. I would like to know if there are any manufacturing standards of record for bucket seats in 1969 model cars and, in particular, whether there were any manufacturing standards for the driver's seat back inboard pivot pin brackets.

Thank you for your cooperation and assistance in this matter.

Very truly yours,

Patrick J. O'Connor

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