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Interpretation ID: nht72-3.32

DATE: 05/08/72

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Stylar Industries Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of March 22, 1972, on the subject of the application of Motor Vehicle Safety Standard No. 207 to the type of swivelling seat manufactured by your company.

We understand from your letter that you are concerned about the type of swivelling seat that is not continuously fastened to its base and that can therefore come loose in a rollover accident. To avoid this problem, you have designed your seat with a stud bolt that links the seat to its base regardless of the amount of rotation. Your question to us is whether removal of the stud bolt would cause the seat not to conform to Standard 207.

The answer to your question depends in part on whether the seat without the bolt would be able to meet the applicable strength requirements of the standard. Removal of the stud belt would not, in itself, cause the seat not to conform to the standard. The seat would conform to S4.3 if the seat were to lock itself by means other than the bolt when returned to the forward facing position.