Mr. Gary Gawura
Program Manager
Track Corporation
1091 Centre Drive
Suite 210
Auburn Hills, MI 48236

Dear Mr. Gawura:

This responds to your letter concerning Standard No. 207, Seating Systems and Standard No. 210, Seat Belt Assembly Anchorages as they apply to a seat design having an upper seat belt anchorage integrated into the seat and lower seat belt anchorages integrated into the adjuster. I apologize for the delay in responding.

You ask several questions regarding the proper test procedures for designs such as yours where the seat belt assembly anchorages are integrated into the seat rather than attached to the vehicle itself. Your letter contains a description and diagram of the current test procedure used by your company to test seats and seat belt anchorages. You indicate that in order to test the belt anchorages, a 3000 pound load is applied to the shoulder and the lap belts as specified in S5.2 of Standard No. 210. You also indicate that a "C.G. force at 20 times the weight of the seat is applied to the seatback and another C.G. force a t 20 times the weight of the pedestal is applied to the pedestal. These loads are held for ten (10) seconds."

The first question you ask is whether it is necessary, under your current test procedure as described above, to apply a load to the pedestal because, as a seat manufacturer, you are not certifying the attachment of the seat to the vehicle.

Depending on the standard involved, Federal motor vehicle safety standards may apply to a manufacturer of motor vehicle equipment, to a vehicle manufacturer or to both. S2 of Standard No. 209 specifies that the standard applies "to passenger cars, multipurpose passenger vehicles, trucks and buses. Therefore, the manufacturer of the vehicle is responsible for ensuring that the product meets the requirements of Standard No. 209. Given the fact that Standard No. 209 requires that the seat be installed in a vehicle when compliance testing is performed, it may not be possible for your company to perform such testing.

If, as your diagram indicates, the load being applied to the pedestal portion of the seat is intended to be the load which must be applied to cg2, the center of gravity of the portion of the seat below the adjuster, as required by S5.1.1(c), a vehicle manufacturer would be required to ensure that the seat assembly met those requirements. As a seat manufacturer, your company is not obligated to do so.

You also ask that the agency comment on a proposed test procedure which your company believes would be more appropriate for testing seats with integrated seat belt anchorages for both lap and shoulder belts. As depicted in a diagram in your letter, this test applies a 3000 pound load to the lap and shoulder belt anchorages and a 20g load to the seat back and the seat "pan."

Your diagram refers to the load applied to the seat back as the upper CG load and the load applied to the seat "pan" as the lower CG load. As the seat "pan" in the seat depicted in your diagram is above the adjuster, the lower CG load shown in this diagram is presumably not the actual lower CG load but rather represents your nomenclature for the load that would be applied to cg2 under S5.1.1(c).

The test that your company proposes clearly does not meet the current requirements of Standard No. 207. It is not clear from your letter if this test is performed with the seat attached to the vehicle. If it is not, the test would obviously not test the strength of the attachment of the seat to the vehicle. Secondly, it is not possible to evaluate your proposed test from the information contained in your letter. However, it appears that the test you propose would place greater loads on the seat frame and adjuster than the current requirements of S5.1.

Finally, you ask for a complete set of standards and rulings related to the testing of integrated adjusters and seats. The requirements for seat belt anchorages are found in S5 of Standard No. 210. As you are aware, the requirements for seats are found in S5.1 of Standard No. 207. Copies of these standards are enclosed as well as the accompanying test procedures.

NHTSA is currently studying possible changes to Standard No. 207 as well as an October 28, 1997 petition for rulemaking submitted by Bornemann Products, Inc. requesting that the agency initiate rulemaking to modify Standard No. 207 in regard to the testing of integrated seats.

I hope that this is responsive to your inquiry.

If you have any questions, please contact Otto Matheke of my staff at (202) 366-5253.

Sincerely,
John Womack
Acting Chief Counsel
ref:207
d.4/1/98