Interpretation ID: nht93-2.28

DATE: March 25, 1993

FROM: Jose M. Gonzalez -- Engineering Manager, Kustom Fit

TO: Office of Chief Council -- NHTSA

COPYEE: Ed Jetner -- NHTSA 208 Engineer; Ron Belk -- KF President; Bob Barras -- KF of Ohio

TITLE: Re: Baseline Sled Testing Evaluation

ATTACHMT: Attached to letter dated 5-6-93 from John Womack to Jose M. Gonzalez (A41; Std. 208; VSA 108(b)(2)

TEXT: We are a manufacturer of seating products for the recreation industry. We have been in business since 1956. We do follow and test our products for your established standards. Since early 1991, we began testing our products dynamically using HIGE Sled Testing laboratories. We have been successfully obtaining good results that are under 20% or more than the maximum requirement criteria with one exception, the General Motors G Van. We have done 4 tests using Hybrid III dummies and we have improved the results with every test. However, we can't achieve the same levels of confidence that we have achieved with other vehicles. We would like to hear your opinion for the following approach:

We would perform two tests: The first being a baseline HIGE sled test using all OEM hardware and seats and the second one with OEM hardware and our seats. The results would then be compared as follows:

If the results of the test using our seats are equal or better than those obtained values with the OEM seats and hardware, does this test prove that our seats are safe to use instead of OEM? Can these results and procedures be acceptable as do diligent and can our seats then be certified for use in these vehicles regarding FMVSS 208?

Your response to this request will be highly appreciated.