Interpretation ID: reversibleseat

Mr. Michael S. Hemenway
8389 Pleasantview Drive
Mounds View, MN 55112

Dear Mr. Hemenway:

This responds to your letter concerning the concept of "reversible front automobile seating".You stated that the concept involves an automobile seat that can be manipulated to face either the normal, forward-facing direction or a rear-facing direction, allowing the occupant to face the second row of seating. You specifically asked whether such a reversible automobile seat would be "allowed in the marketplace without . . . crash testing," if it was clearly stipulated that the reversible seat can only be used (1) when the vehicle is not in a drive gear ("Park" or "Neutral" w/parking brake), and (2) when the reversed seat is unoccupied by a person during travel.

By way of background, the National Highway Traffic Safety Administration (NHTSA) is authorized to issue Federal motor vehicle safety standards (FMVSSs) that set performance requirements for new motor vehicles and items of motor vehicle equipment. NHTSA does not provide approvals of motor vehicles or motor vehicle equipment. Under 49 U.S.C. Chapter 301, it is the responsibility of the manufacturer to ensure that its vehicles or equipment comply with all applicable requirements.

We have issued a number of safety standards related to seats and occupant protection, including, but not limited to, Standard No. 201, Occupant protection in interior impact, Standard No. 207, Seating systems, Standard No. 208, Occupant crash protection, Standard No. 209, Seat belt assemblies, Standard No. 210, Seat belt assembly anchorages.

In asking whether a reversible automobile seat would be allowed in the marketplace without crash testing in certain situations, I assume you are asking whether the vehicle would be subject to our crash test requirements with the seat in the rear-facing position. I note that the general issue of how a vehicle with reversible seats would be tested is relevant not only to crash test requirements, but also to various other requirements such as ones on seat strength, seat belts, and so forth.

In order to provide a complete answer to your question, it would first be necessary to identify and analyze each potentially relevant requirement, including any specified test procedures, to determine how the requirement would generally apply to a reversible seat in the rear-facing position. It would then be necessary to analyze whether the requirement would apply differently in special situations. While we are able to respond to specific requests for interpretation, we do not have the resources to provide this type of detailed analysis.

I would observe that, assuming a vehicle is subject to a particular test requirement with a reversible seat in the rear-facing position, the vehicle would not be excluded from that requirement merely because a warning was provided that the seat was not to be occupied in that position when the vehicle was in motion. A vehicle might be excluded if the reversible seat could only be used in its forward-facing position while the vehicle is in motion. However, we would need to know more about the specific vehicle design before providing an interpretation, and would only provide it in the context of a specific test requirement.

Enclosed is an information sheet for new manufacturers of motor vehicles and motor vehicle equipment. I hope you find this information helpful. If you have further questions, you may contact Edward Glancy of my staff at (202) 366-2992.

Sincerely,

Jacqueline Glassman
Chief Counsel

Enclosure
ref:208
d.7/11/05