Interpretation ID: nht81-3.41

DATE: 11/18/81

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Mazda (North America), Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your recent letter requesting an interpretation regarding Safety Standard No. 207 as it would apply to a new seat design your company is considering. This design includes additional seat track forward of the seat track positions that are included as normal riding positions. Since there are no locking positions on this additional seat track, the vehicle seat cannot comply with the loading requirements of Standard No. 207 when in this position. Those requirements must be satisfied in any position to which a seat can be adjusted. You ask whether the extended track would be considered part of the seat track for purposes of Standard No. 207 and for purposes of the adjustment requirements in testing under Safety Standard No. 208.

The answer to your question is yes unless some mechanism is included which will automatically return the seat to a locked position on the track when the seat back is in its upright position and no force is being applied. Most motor vehicle seats will travel some short distance forward of the forward-most adjustment locking position. However, they are designed to return to the nearest locked adjustment position when the adjusting force is removed from the seat, i.e., when the occupant releases the adjustment lever and stops pushing the seat forward. Many seat designs accomplish this result by spring-loading the seat. Therefore, the seat track portion labeled "A-B" in your diagram would not be considered part of the seat track for purposes of Safety Standard No. 207 and Standard No. 208 if the seat is designed to return automatically to position "B" and lock when the seat back is in its upright riding position.

None of the other alternative solutions you mentioned would be sufficient. All of the alternatives fail to prevent the seat with its seat back in the upright position from being adjusted to a position on the "A-B" portion of the track, all of which are unlocked positions. With one limited exception, none of the alternatives would aid the seat in meeting the forward and rearward loading requirements when the seat is adjusted somewhere on the "A-B" portion of the track. The exception concerns the alternative of strengthening the stopper at the "A" position. This alternative might enable the seat to meet the forward loading requirements of Standard No. 207, but only when the seat was adjusted to the "A" position on the "A-B" portion of the track. The seat would not be able to meet the aft loading requirements at the "A" position, however.

I would like to point out that the agency does not provide advance approval of any device or element of design in a motor vehicle. The National Traffic and Motor Vehicles Safety Act makes the vehicle manufacturer responsible for determining whether its vehicles are in compliance with all applicable safety standards and for certifying that compliance. This letter only represents the agency's informal opinion based on its understanding of the information supplied in your letter.

Also, if you desire to have the information concerning this seat design treated as confidential business information by the agency, you will have to submit sufficient information to justify such treatment. I am enclosing proposed guidelines for seeking confidential treatment. If you do not choose to follow this procedure, we will have to place this interpretation in our public redbook file for the benefit of all interested persons.

ENC.