Interpretation ID: nht88-1.89

TYPE: INTERPRETATION-NHTSA

DATE: 04/08/88

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Isuzu Motors America, Inc.

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. Takashi Ohdaira Isuzu Motors America Inc. 21115 Civic Center Drive Southfield, MI 48076-3969

Dear Mr. Ohdaira:

This responds to your December 16, 1987 letter asking several questions about the applicability of Federal Motor Vehicle Safety Standard No. 207, Seating Systems, to "swivel type front seats" installed in new compact passenger vans. I regret the delay in responding. Swivel seats are not prohibited by Standard No 207. However, under Standard No. 208, Occupant Crash Protection, a front outboard swivel seat must have lap and upper torso restraints that fit the occupant of the seat in any position in which the seat would be occupied while the vehicle is in motion, including the rearward facing position.

Your letter explains that Isuzu is interested in manufacturing some of its vehicles with swivel seats for the driver and front outboard passenger. The seats can be rotated in any direction and self-locked into either a forward-facing or a rearward-facing direction. A release control is provided allowing the seat to be rotated into a new position. You state that Isuzu tentatively plans to install lap and upper torso belt assemblies with emergency-locking retractors that "meet the requirements applicable to a forward-facing front seat" since the capability of the seats to face rearward is "just a secondary function."

You first ask for confirmation of your understanding that Standard No. 207 does not prohibit the installation of front outboard swivel seats. Your understanding is correct. Our standards do not require seats on vehicles other than large school buses to b e forward-facing and thus do not thereby expressly prohibit installation of swivel seats.

Your letter raises the issue of whether the swivel seat installed at the front outboard passenger seating position must comply with the requirements of Standard No. 208 and thus provide lap and upper torso restraints only for the forward-facing position (as opposed to what you term the "secondary" or rearward position). Paragraph S7.1.1 of Standard No. 208 states, in pertinent part: . . . The lap belt of any seat belt assembly furnished in accordance with S4.1.1 and S1.1.2 shall adjust by means of an em ergency-locking or automatic-locking retractor that conforms to S571.209 to fit persons whose dimensions range from those of a 50th-percentile 6-year-old child to those of a 95th-percentile adult male and the upper torso restraint shall adjust by means o f an emergency-locking retractor or a manual adjusting device that conforms to S571.209 to fit persons whose dimensions range from those of a 5th-percentile adult female to those of a 95th-percentile adult male with the seat in any position and the seat back in the manufacturer's nominal design riding position. . . . (Emphasis added.)

The quoted reference to seat "position" in the excerpt from S7.1.1 is not limited to the positions along the vehicle longitudinal centerline to which a seat can be adjusted while forward-facing. We interpret the term as referring also to seat orientation , including the rearward-facing position or any other direction the seat is capable of facing, provided that the seat can be placed in those positions while the vehicle is in motion. Thus, we believe that a front outboard swivel seat must have lap and up per torso restraints that fit the occupant of the seat while the seat is in any position in which it can be occupied while the vehicle is in motion. Starting September 1, 1991, light trucks and multipurpose passenger vehicles with manual safety belts for the driver and front seat passenger seating position will have to meet the requirements of Standard No. 208 in a dynamic crash test. A front outboard swivel seat would have to comply with those requirements with the seat in any position in which it can be occupied while the vehicle is in motion.

We have limited our interpretation to positions in which a seat may be occupied while the vehicle is in motion for the following reasons. The purpose of requiring a seat belt assembly to meet the adjustment requirements of Standard No. 208 with the seat in any position is to ensure that adequate occupant crash protection would be provided to the occupant of the seat regardless of the position he or she chooses for the seat. However, the safety goal of ensuring adequate crash protection for vehicle occup ants relates only to positions in which a seat may be occupied when a vehicle is involved in a crash, i.e., the positions in which a seat may be occupied while a vehicle is in motion. If the swivel seat you plan to install for the front outboard seating position can only be used in its forward-facing position while the vehicle is in motion, then it need meet Standard No. 208's requirements only at forward facing positions and need not conform with the standard's requirements at positions facing in other directions.

In your letter, you suggested the possible ways to limit the rearward-facing capabilities of a front outboard swivel seat. First, you suggested that the vehicle could be manufactured with an interlock system that would prevent the vehicle from starting u nless the front passenger seat faces forward. In our opinion, this system would not sufficiently ensure that the swivel seat would be used only in its forward-facing position while the vehicle is in motion. An occupant of the seat could swivel his or her seat once the vehicle has started and could thus face rearward without the benefit of lap and upper torso restraints.

Your second suggestion has to manufacture the vehicle such that the front passenger seat could swivel rearward only when the driver seat rotated rearward or when the vehicle was "in park." This would prevent the passenger's seat from facing in any direction other than forward while the vehicle was in motion since the driver must face forward to operate the vehicle. We believe that this alternative could satisfactorily ensure that the front outboard p assenger seating position could not face in any direction other than forward while the vehicle is in motion.

In addition to the requirements discussed above, we note also that Standard No. 210, Seat Belt Assembly Anchorages, would require the front outboard swivel seat to have seat belt anchorages for a Type II seat belt assembly. The anchorages would have to m eet the standard's strength requirements (S4.2), and those for their location (S4.3) provided that the safety belt will not be dynamically tested pursuant to Standard No. 208's requirements. Anchorages for a front outboard swivel seat that can be occupie d in its rearward facing position while the vehicle is in motion could be tested to the requirements of 54.2 by the agency with the seat in either the forward or rearward facing position.

I hope this information is helpful. Please contact us if you have any questions.

Sincerely,

Erika Z. Jones Chief Counsel

December, 16, 1987

Ms. Erika Z. Jones Chief Counsel National Highway Traffic Safety Administration 400 Seventh Street. S. W. Washington. D. C. 20590

Dear Ms. Jones:

Subject: Swivel Type Seats - Interpretation

This letter is intended to seek your agency' s advice on the interpretation of Federal Motor Vehicle Safety Standards (FMVSS) as they related to the swivel type front (first row) seats which Isuzu Motors is planning to use for its compact passenger vans.

This van will have two swivel seats in the first row, one for the driver and the other for front seat passenger. These seats are used as forward-facing seats when the vehicle is in motion but while in park they can be swiveled 180 degrees to face rear-wa rd. The swivel mechanism has a self-lock which locks the seat in position as it is turned every 780 degrees. The users manually manipulate a release control to swivel the seat. An example of how these seats are used is shown in the Attachment.

Since the rearward-facing is just a secondary function of these seats, Isuzu Motors is planning to design these seats to meet the requirements applicable to a forward-facing front seat and a forward-facing front outboard designated seating position. that is, FMVSS 207, 208 and 270. Therefore, Type 2 seat belt assemblies with emergency locking retractors will be installed for both the driver and front seat passenger.

The following is our understanding and questions on FMVSS compliance. I would appreciate receiving your answer to these questions along with any comments you may have.

1. FMVSS does not prohibit using swivel seats in the first row or this type or vehicles. Is this understanding correct?

2. While the vehicle is in motion, the front passenger may want to remain facing rearward. Is such a condition permissible under FMVSS?

3. If the front passenger seat were required to face forward while the vehicle is in motion. Isuzu Motors is considering either of the following arrangements. I would request your comments on these plans:

a. The vehicle does not start unless the front passenger seat faces forward.

b. The front passenger seat swivels together with the driver seat and hence faces forward while the vehicle is being driven.

I would appreciate receiving your answer or comments at your earliest convenience since Isuzu would like to start its design work soon.

Sincerely yours,

Takashi Ohdaira Chief Representative Emission & Safety

/jj c: Mr. Fukuhara, Isuzu Motors, Japan