Interpretation ID: nht72-1.40

DATE: 08/16/72

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Nissan Motor Company, Ltd.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letters of July 25 and 28, 1972, on the subject of the positioning of seat backs for the purposes of testing under Standards No. 208 and 210.

The "nominal design riding position" specified in Standard 208 and formerly employed in Standard 210 is the position considered by the manufacturer as that most likely to be used by vehicle occupants. In our compliance tests, we ask the manufacturer of each vehicle to be tested to advise us of the correct position.

The term "most upright position" used in Standard 210 was adopted in part to avoid the need to go to the manufacturers for advice each time we tested a vehicle's seats. Under S4.3.2 of the standard, the seat back is adjusted to the position which places the seating surface most nearly in a vertical position.

There have, however, been difficulties with the use of the "most upright position", in cases where that position is not the same as the position used by the manufacturer to establish the seating reference point. Because S4.3.2 also calls for the positioning of the SAE J826 mannikin on the seating reference point, there is a possibility that the manikin cannot be correctly positioned. This does not appear to be a serious discrepancy, but it is one that should be resolved, and we intend to do so by appropriate amendment in the Federal Register.