Interpretation ID: nht93-7.5

DATE: October 1, 1993 Est.

FROM: John Womack -- Acting Chief Counsel, NHTSA

TO: Tom DeLapp -- Executive Coach Builders, Inc.

TITLE: None

ATTACHMT: Attached to letter dated 8/18/93 from Tom DeLapp to Chief Council, NHTSA (OCC-9085)

TEXT:

This responds to your letter of August 18, 1993, concerning a modification you wish to make on limousines manufactured by your company. You wish to modify the hinge assembly controlling forward and reclining movement of the front seat to provide access to the area between the front of the privacy panel and the back of the front seat. (The area contains auxiliary fuse panels and relays.) The modification would involve removal of a metal pin in the hinge assembly, allowing the seat to articulate forward to a greater degree. You asked whether Standard No. 207, Seating Systems, prohibits the removal of a limiting pin or limits forward movement of a seat back.

Standard No. 207 specifies strength and other performance requirements for seats in passenger cars, multipurpose passenger vehicles, trucks, and buses. Section S4.3 of Standard No. 207 contains requirements for hinged or folding seat backs, except for passenger seats in buses or a seat adjustable only for its occupants. Section S4.3(a) requires a self-locking device for restraining the hinged or folding seat back. Section S4.3.2 contains performance requirements for this restraining device.

Section S4.3 does not limit the degree of movement of a hinged or folding seat back. Thus, you may remove the limiting pin if removing it only increases the degree of movement of the seat. However, the seat must still meet the requirements of S4.3 with the pin removed. Accordingly, the seat must have a self-locking device that can withstand the force applications specified in S4.3.2.1 and acceleration specified in S4.3.2.2.

I hope you find this information helpful. If you have any other questions, please contact Mary Versailles of my staff at this address or by phone at (202) 366-2992.