Interpretation ID: nht95-1.56

TYPE: INTERPRETATION-NHTSA

DATE: February 7, 1995

FROM: Philip R. Recht -- Chief Counsel, NHTSA

TO: Thomas J. Leffler -- Developmental Shop Manager, Findlay Industries, Inc.

TITLE: None

ATTACHMT: ATTACHED TO 11/8/94 LETTER FROM THOMAS J. LEFFLER TO PHILIP RECHT

TEXT: Dear Mr. Leffler:

This responds to your letter of November 8, 1994, asking whether S4.3 of Standard No. 207, Seating Systems, requires a self-locking device to restrain the seat cushion of a particular seat design in the down position. The seat "has a storage box below t he seat cushion frame. To access the storage space, the seat cushion pivots up to allow entry into the box." If a self-locking device is required, you asked whether static or dynamic testing is required for the device.

Section S4.3 of Standard No. 207 requires "a hinged or folding occupant seat or occupant seat back" to be equipped with a self-locking restraining device. NHTSA does not consider the words "occupant seat or occupant seat back" to refer to the seat cushio n alone, and therefore a restraining device for the cushion alone is not required.

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.