Interpretation ID: nht94-4.37

TYPE: INTERPRETATION-NHTSA

DATE: September 28, 1994

FROM: Paul N. Wagner, President, Bornemann Products, Inc.

TO: Mary Versailles -- Office of the Chief Counsel, NHTSA

TITLE: Re: F.M.V.S.S. #207 Seating Systems

ATTACHMT: ATTACHED TO LETTER DATED 12/23/94 FROM PHILIP R. RECHT TO PAUL N. WAGNER (A42; STD. 207); ALSO ATTACHED TO LETTER DATED 8/26/88 FROM ERIKA Z. JONES TO GLENN L. DUNCAN

TEXT: Request for Comment From Chief Counsel:

Earlier this year, the Agency amended F.M.V.S.S. #208 for seat belt comfort and fit by requiring in the future that designated seating positions have either an adjustable "D" ring or seat belts integrated into the seat (integrated seats). This letter is directed to an issue concerning integrated seats. An integrated seat is defined for now as a seat or seat system that the seat belts are located on the seating structure, in an all-belts-to-seat application; the pelvic portion of the belt may be attache d to the seat bottom, seat slides, or seat riser, while the "D" ring and shoulder belt is actually attached to the back of the seat itself.

Our firm is a manufacturer of seating systems for light trucks manufactured in more than one stage, and is considering the manufacture of integrated seating systems.

The questions we pose, which may already be before the Agency, are ones that relate to testing requirements for integrated seating. Referring to F.M.V.S.S. #207, S4.2.1, which states:

"SEAT ADJUSTMENT. Except for vertical movement of nonlocking suspension type occupant seats in trucks or buses, the seat shall remain in its adjusted position during the application of each force specified in S4.2."

Subparagraph S4.2 refers to specific static requirements for seating systems. When a seat belt system, such as those on integrated seats, are attached to the seating system, then the static loads of F.M.V.S.S. #207, S4.2, and F.M.V.S.S. #210, S4.2, are p erformed simultaneously.