Interpretation ID: nht78-3.12

DATE: 07/20/78

FROM: AUTHOR UNAVAILABLE; M. M. Finkelstein; NHTSA

TO: Hon. John Glenn -- U.S. Senate

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of June 7, 1978, pertaining to your constituent's, Mrs. Carl A. Koch, concerns regarding motor vehicle seat backs that do not permanently lock.

Federal Motor Vehicle Safety Standard No. 207, Seating Systems, copy enclosed, requires that hinged or folding occupant seat or occupant seat back shall be equipped with a self-locking device for restraining the hinged or folding seat or seat back and a control for releasing that restraining device. The industry is currently installing two types of seat back latches, a manual conventional type of latch and a new inertial locking device. The standard requires that the locks withstand a load 20 times the weight of the hinged portion of the seat and is not required to withstand the load of an occupant striking the seat back. Rear occupants are expected to be restrained by the rear seat belts, however, seat backs in locked position, because of some padding, do provide some protection for unrestrained occupants.

The seat back latch referred to by your constituent is an inertial seat back latch which is neither required nor prohibited by the standard. The industry, in an effort to facilitate rapid egress from a motor vehicle in emergency situations, such as a fuel fire, have introduced inertial seat back latches. The seat back latch will lock when the low forces of a panic breaking situation occurs or a high impact force occurs, releasing itself automatically when the inertial forces drop to a predetermined force, normally approximately .5g, allowing rapid occupant egress.

We believe there can be positive post-crash escape advantages for the inertial type seat back latches, however, it would appear from Mrs. Koch's experience that it may be warranted to initiate an investigation of the type of inertial latches installed in the 1978 Ford Granada. Accordingly, I am forwarding a copy of your letter to our Office of Defects Investigation for their action to determine if and what corrective action may be warranted.

I hope this information is helpful to you in responding to Mrs. Koch's inquiry. If I can be of further assistance, please let me know.

SINCERELY,

Michael M. Finkelstein Acting Associte Administrator for Rulemaking

June 2, 1978

Dear Senator Glenn,

I have no idea who to write to about what I consider a major problem and since your name and address was listed in the paper and I voted for you I am asking you to get my complaint to the right person.

I recently purchased a 1978 Ford Granada, two door car. No one told me that the seats now do not lock permanently in place and must be released. A small truck with no stop lights on back caused me to brake real fast and my eight year old was sitting on the end of the back seat and the seat acted as a slide when it fell forward and propelled my daughter right up into the windshield. I took it to the service department and have even written Ford Motor Company and they tell me that they cannot lock this seat for me as Ralph Nader has made them put in this kind of seat. They further told me that until I have an accident and maybe kill one of my little ones by having them fly out the windshield they have no way of proving wether my seats actually lock on rapid decellaration. There could be a malfunction and they have no way of checking it out. I can't believe that if you could fly in outer space there isn't something that could be done to give you a choice of wether we want our seats locked while we are driving or wether we prefer them to be movable. If no one is in the car and you stop fast the seat flies forward. It is a distraction and safety hazard. When a child is old enough to open a seat belt it is impossible to keep him in them if he wants to be able to see out the side or front window. I bought a two door car because I have eight children from twenty six to six and I want them confined while I am driving where if anything happens they will receive the least injury possible. With locked seats and no doors to open or windows to open the child is farely safe and I have never had a scare like the incedent that I related at the beginning of my letter.

I am sorry but I think Ralph Nader has made a big goof and who ever in government that is responsible for helping him make this change in automobiles better take a second look and do some more testing. I feel the manufacturer should also be required to have some way of testing to make sure that if I have an accident that these seats are going to lock as we are told they will. I have taken this car out in the country and slowed rapidly, stopped fast and done everything short of hitting a brick wall and these seats will not lock.

Thank you for getting my complaints to the right person,

Dolores A. Koch (Mrs. Carl)