Mr. Paul Wagner
Bornemann Products Incorporated
402 Industrial Drive
P.O. Box 427
Bremen, IN 46506

Dear Mr. Wagner:

This responds to your letter concerning Federal Motor Vehicle Safety Standard No. 207, Seating Systems, as it applies to a seat design having a reclining mechanism and an upper seat belt anchorage integrated into the seat. I apologize for the delay in responding.

Confirming your understanding, Standard 207 applies to an integrated seat "as currently provided." The integrated seat must meet the general performance requirements of S4.2, the requirements of S4.2.1 for seat adjusters, and unless excepted, the requirements in S4.3 for a restraining device for hinged or folding seats or seat backs.

You are concerned that a reclining mechanism on an integrated seat that adjusts only for comfort would not be adequately evaluated under Standard 207. The seat would be excluded from S4.3 under the terms of that section because it would be "a seat having a back that is adjustable only for the comfort of its occupants." While the seat would be subject to the general performance requirements of S4.2, you state that the test procedure is inadequate for the recliner because much of the load placed on the seat and seat belt anchorage would be absorbed by the side struts described in S5. You state: "In real life, an integrated seat may experience movement from one adjustment position to another, as in a change in detent of the seat recliner due to the shearing of the recliner's teeth, but yet in the lab scenario, still comply with the test requirements in Standard No. 207."

The exclusion from S4.3 for seat backs which adjust only for the occupant's comfort is very limited. If a seat back also adjusts for any other reason, i.e. to allow access to other areas of the vehicle or to provide additional range of adjustment for seat belts, the seat would be required to have a restraining device which meets S4.3.

I also would like to take this opportunity to respond to your comment that a seat may experience movement from one adjustment position to another and still comply with Standard 207's requirements. As S4.2.1 applies to adjustment of the seat back as well as the seat itself, the seat back of an integrated seat with a reclining mechanism must remain in its adjusted position when tested under the procedures outlined in S5.

We also note that your letter suggests establishing test procedures for integrated seats. NHTSA is currently studying possible changes to Standard No. 207 as well as the October 28, 1997 petition for rulemaking submitted by your company.

I hope you find this information helpful. If you have any other questions, please contact Otto Matheke at this address or by phone at (202) 366-5253.

John Womack
Acting Chief Counsel