Search Interpretations

Interpretation ID: positioningSID_VenieroPizzagalli

    Mr. Veniero Pizzagalli
    Ferrari S.p.a.
    Abetone Inferiore 4
    Maranello MO Italy 41053 P


    Dear Mr. Pizzagalli:

    This responds to your letter asking about Federal Motor Vehicle Safety Standard (FMVSS) No. 214, Side Impact Protection, concerning the positioning of the Side Impact Dummy (SID) for purposes of conducting the FMVSS No. 214 moving deformable barrier (MDB) test. You are having difficulty in placing the SID in a new sport seat that will be mounted in some of your future cars.

    S7 of FMVSS No. 214 specifies positioning procedures for the SID. S7.1.1 and S7.1.2 specify that a SID placed in a bucket seat at the drivers seating position and at the right front passenger seating position, respectively, is to be positioned such that "[t]he upper torso of the test dummy rests against the seat back. " The standard also specifies, at S7.2.1, that the H-point of the dummy is to coincide within inch in the vertical dimension and inch in the horizontal dimension of a point inch below the position of the H-point determined by using the equipment for the 50th percentile and procedures specified in SAE J826 (with certain exceptions). In addition, the standard specifies, at S6.4, that adjustable seat backs are placed in the manufacturers nominal design riding position in the manner specified by the manufacturer. S6.4 states that, if the position is not specified, the seat back will be set at the first detent rearward of 25 from the vertical.

    You state in your letter that, when the SID is placed in the sport seat, there is a space of 78 mm from the back of the dummy to the seat back. The middle of the dummys back cannot rest against the seat because the torso makes contact with the "wings" of the seatback. You suggest five different ways that the dummy could be positioned in the seat and ask if any of these are acceptable to the National Highway Traffic Safety Administration (NHTSA).

    NHTSA would not use the first four options you suggest. The first approach you suggest involves resting the dummys torso against the wings of the seat but not having the H-point of the dummy in the zone described by S7.2.1. NHTSA would need to

    position the H-point as specified in S7.2.1. Your second option calls for forcing the dummy into the seat and against the seat back, possibly using tape or a harness to hold the dummy against the seat back. We would prefer not using artificial means to restrain the dummy in the test. The third option you suggest is to cut a portion of the dummys partial arms or remove them, thereby avoiding contact of the arms with the seat wings. We cannot modify the SID as you suggest other than through a rulemaking proceeding. Your fourth option involves reclining the seat back such that the dummys back is reclined at a 25 tilt angle. We would not use this fourth approach because the seat back angle will be greater than 25 degrees and the dummys back does not make contact with the seat back.

    Your fifth approach appears usable. This approach involves tilting the seat back such that the dummys back contacts the seat back at the wings. We would consider the wings of the seat to be part of the seat back, so contact with the wings satisfies the provision that the dummy contact the seat back. The H-point of the dummy would be maintained in the permitted tolerance zone of S7.2.1. The seat back would be positioned as specified in S6.4. The dummys back angle will be less than 25 degrees, but the test procedures do not specify that the angle of the back must be 25 degrees.

    I hope this answers your questions. If we can be of further assistance, please contact Deirdre Fujita of my staff by telephone at (202) 366-2992 or by fax at (202) 366-3820.

    Sincerely,

    Stephen P. Wood
    Acting Chief Counsel

    ref:214
    d.11/3/05