Interpretation ID: nht94-4.88

TYPE: INTERPRETATION-NHTSA

DATE: November 28, 1994

FROM: Melinda Dresser -- Manager Contracts/Transportation, Carlin Manufacturing

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

TITLE: RE: Swivel Seats

ATTACHMT: Attached to 1/13/95 (est.) letter from Philip Recht to Melinda Dresser (A43; Std. 207)

TEXT: Carlin Manufacturing, Inc. is a manufacturer of custom mobile kitchens and specialty vehicles, using manufacturing license #23791. We are currently manufacturing two (2) Command Post Vehicles for the California Highway Patrol. We are installing a driver and front passenger seat with a swivel base. We were informed from several seat manufacturers and vendors, that swivel bases on seats are not allowed per 49 C.F.R. part 571 section 207 and 208.

On November 4, 1994, you were kind enough to fax me a letter regarding a similar type of application. The letter dated November 25, 1992, stated there wasn't a Federal law prohibiting a person from adding a swivel base to a seat. However, installation must be done in such a way that the seats and safety belts continue to provide the safety protection mandated by the safety standards.

Even though I still don't find any restrictions in section 207 and 208, we are requesting a current written determination from your office.

If you should have any questions or need clarification, please feel to call contact me at 209/276-0123. Thanking you in advance.