Interpretation ID: nht95-3.4

TYPE: INTERPRETATION-NHTSA

DATE: June 7, 1995

FROM: Helen A. Rychlewski -- MGA Research Corporation

TO: John Womack -- Acting Chief Counsel, NHTSA

TITLE: NONE

ATTACHMT: ATTACHED TO 08/4/95 LETTER FROM JOHN WOMACK TO HELEN A. RYCHLEWSKI (A43; REDBOOK 2; STD. 201)

TEXT: Dear Mr. Womack:

This letter is in regard to a request for legal interpretation falling under the regulations of Federal Motor Vehicle Safety Standard (FMVSS) 201- Occupant Protection in Interior Impact. MGA Research Corporation is an independent automotive safety te sting laboratory. FMVSS 201 falls under my testing responsibilities at MGA. Recently, I was requested to conduct FMVSS 201 impacts on a front bucket seat.

The seat has an inertial latch on the recliner. During the first few tests, the seat back dumped forward due to the inertial latch not engaging. Then, my customer requested that the inertial latch and adjustable tracks be welded in place to avoid th e previous test result. I conducted a test under such conditions and the seat back did not dump forward. In my final test report, my customer would like me to make a statement that says that this seat "passes" FMVSS 201 and all its criteria are met. I would like to obtain a legal interpretation of FMVSS 201 relative to pre- and post-test latch position and its view on inertial latches.

Your help in this matter is greatly appreciated.