Interpretation ID: nht94-4.76

TYPE: INTERPRETATION-NHTSA

DATE: November 8, 1994

FROM: Thomas J. Leffler -- Development Shop Manager, FINDLAY INDUSTRIES, INC.

TO: Philip Recht -- Chief Council, NHTSA

TITLE: None

ATTACHMT: ATTACHED TO 2/7/95 LETTER FROM PHILIP R. RECHT TO THOMAS J. LEFFLER (A43; STD. 207)

TEXT: Dear Sir:

After talking with Mr. Ed Glancy on the telephone on November 3, 1994, I am making a formal request for an interpretation and ruling on a seat test requirement.

Findlay Industries has a seat design (see attached sketch) that has a storage box below the seat cushion frame. To access the storage space, the seat cushion pivots up to allow entry into the box. This is where the question arises.

In referencing our code of Federal Regulations Book for Transportation (# 49/parts 400 to 999, revised as of October 1, 1990) Part 571.207 Standard No. 207; Seating Systems Section S4.3 (pages 416-417) "Restraining device for hinged or folding seats or s eat backs", we are unsure as to the necessity of our design to comply with this section of Standard 207.

Our seat design, as you can see, only pivots the seat cushion out of the way for access while the remainder of the seat system is a rigid assembly. Does our cushion frame require a self-locking device for restraining the hinged or folding seat in the do wn position as stated in Section S4.3? If so, is static or dynamic testing required for this self-locking device?

I would ask for your attention and interpretation as soon as possible due to our production timing and the time required due to any changes deemed necessary by your ruling.

Thank you for your assistance.

attachment

(Drawing of 2/3 seat - # 2025351 omitted.)