Interpretation ID: nht93-1.46

DATE: February 22, 1993

FROM: Cleo Betts -- Director of Engineering, Coachmen Recreational Vehicle Company

TO: Mary Versailles -- Office of Chief Council, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 4-30-93 from John Womack to Cleo Betts (A41; Std. 207; Part 571)

TEXT: Thank you for your assistance in answering my questions relative to free standing furniture in a motorized vehicle and I appreciate your offer to provide a written interpretation of the standards. As we discussed, my questions deal with a dinette and associated chairs in a moving motorhome.

To meet regulatory standards, must the dinette table and its associated chairs be secured to the floor? If the dinette chairs are not secured to the floor, do they qualify as a designated seat position? Should a dinette chair be attached to the floor, must it be a designed seat?

In our phone conversation, you indicated a free standing dinette and chairs would be viewed as temporary furniture and would not be required to meet the federal standards. I also understood labeling is not required but we did discuss that labeling may be more closely associated with product liability then federal regulations.

As you can tell by my questions, we are desirous of developing a motorized recreational vehicle with free standing dinette and chairs. We are very sensitive to complying with federal standards and want to understand how such furniture usage fits within or outside of the standards.

Please identify which sections and paragraph in the standard,that you selected in developing your response. If you would, please include information so I may order the most current standard book.

You were very helpful during our phone conversation and am looking forward to receiving your written reply.