Interpretation ID: 11394

Erika Z. Jones, Esq.
Mayer, Brown & Platt
2000 Pennsylvania Ave. NW
Washington, DC 20006-1882

Dear Ms. Jones:

This responds to your letter of November 27, 1995 concerning the requirement in S4.4 of Standard No. 207, Seating Systems. That section provides that:

Seats not designated for occupancy while the vehicle is in motion shall be conspicuously labeled to that effect.

You requested confirmation that this requirement would not apply to a seat that was equipped with a folding seat back to convert the seat to a bed.

You are correct. NHTSA interprets this requirement as applying only to positions that do not qualify as designated seating positions under 49 CFR 571.3. Therefore, "designated seating positions" that convert to a non-seating use do not have to comply with the labeling requirement of S4.4.

I hope this information has been helpful. If you have other questions or need some additional information, please contact Mary Versailles of my staff at this address or by phone at (202) 366-2992.

Sincerely,

Samuel J. Dubbin Chief Counsel

ref:207 d:1/4/96