ID: 10095

Mr. Reidar Brekke
Market Analyst
Norwegian Trade Council
800 Third Avenue
New York, NY 10022-7604

Dear Mr. Brekke:

This responds to your letter asking about the legality of "Belly Safe," a device to alter the positioning of vehicle lap and shoulder belts, for the advertised purposes of improving the fit of the belts on pregnant women. As described in the material you enclosed, two long straps attached to the "Belly Safe" are attached around the back of the seat. The occupant then sits on the "Belly Safe," attaches the safety belt, brings two straps from the "Belly Safe" up between the legs, and attaches the lap belt through the Velcro on those straps.

The following discussion explains the effect of our regulations on such products and concerns NHTSA has about this specific product.

By way of background information, this agency has the authority to issue safety standards applicable to new motor vehicles and new items of motor vehicle equipment. This agency does not have a safety standard that directly applies to belt positioning devices. Our safety standards for "Occupant Crash Protection," (Standard No. 208) and "Seat Belt Assembly Anchorages" (Standard No. 210) apply to new, completed vehicles. In addition, our safety standard for "Seat Belt Assemblies" (Standard No. 209) applies to new seat belt assemblies. Because the "Belly Safe" is neither installed as part of a completed vehicle nor as part of a seat belt assembly, none of these regulations apply to the device.

While none of these standards apply to the "Belly Safe," the manufacturer of the product is subject to federal requirements concerning the recall and remedy of products with defects related to motor vehicle safety (49 U.S.C. 30118-30121). The agency does not determine the existence of defects except in the context of a defect proceeding. In addition, while it is unlikely that the "Belly Safe" would be installed by a motor vehicle manufacturer,

distributor, dealer or repair business, 49 U.S.C. 30122 prohibits those businesses from installing the device if the installation "makes inoperative" compliance with any safety standard.

NHTSA is concerned that the "Belly Safe" could be used in a way that adversely affects crash forces on the occupant. Standard No. 208 includes requirements that have the effect of ensuring that the lap and shoulder belts distribute the crash forces to the occupant's skeletal structure, a part of the body that can better withstand the forces. For example, Standard No. 208 requires the shoulder belt and the lap belt to intersect off of the abdominal area. The "Belly Safe" places an object between the legs of the occupant. This change in the distribution of crash forces could have serious safety implications for the wearer of the belt.

There are other concerns about the "Belly Safe." The realigning of the lap belt through the "Belly Safe" could increase the amount of webbing in the belt system. If the straps which attach around the back of the seat or the Velcro holding the lap belt are unable to withstand the forces of a crash, there would be excessive slack in the lap belt. Slack in the lap belt would increase the risk of the occupant sliding under the lap belt (submarining) and slack in the belt system generally introduces higher crash forces, both of which would increase the risk of injury. In addition, should a non-pregnant occupant use the "Belly Safe," the device could do more harm than good.

I have enclosed a consumer information sheet titled "Pregnancy: Protecting Your Unborn Child in a Car." This sheet explains that the lap belt should be placed low, across the hips and over the upper thighs. If a woman takes the time to adjust the belt as recommended (an action also needed to install the "Belly Safe"), NHTSA is unaware of any need for a device to keep the lap belt in this position.

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

Sincerely,

John Womack Acting Chief Counsel

Enclosure ref:208 d:7/14/94

ID: nht93-2.44

DATE: April 5, 1993 EST

FROM: :Linda Roberson -- President, Body Safety Kids Club, Inc.

TO: NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 6-25-93 from John Womack to Linda Roberson (A41; Std. 213; VSA 102); Also attached to letter dated 2-25-92 from Paul Jackson Rice to Phil Gray (VSA 108(a)(2)(A)); Also attached to letter dated 9-6-84 from Frank Berndt to Phillip Ables.

TEXT: Dr. Jeff Michael has talked with me this morning, and has very kindly given me your name and information to ask you to consider. I have enclosed two safety harness that I have two patents on. One is to the safety of tethering the child and one is a divisional patent to a safety club and ID system for children. There are several things here that I need information about and I enclosed some information for you to see what the safety club, in the future will evolve into, I hope.

My main concern with your council is for safety also when the child is riding in the car. I would like for these children to have a safety device when they are out with their guardian, and also when they are going to or returning from outings, etc. I have also enclosed a little hanging tag which is to be redone for the harness and to hang on for information. I have corrected some mistakes, and I also want to know what I can say when marketing these little harness. For my older grandson, I use the blue harness and I take the shoulder strap and go down through diagonally to keep it out of his hands and to keep it out of his face area. I would like very much for this to be tested. I have used it on him, but thankfully have never had any accident, or quick stops and I wondered if your testing lab and dummy could test this aspect. For the pink harness I have stapled or pinned a replica of a lap seat belt and how it passes through my harness for the 3 year old, before that age, they are in car seats. I say 35 pounds for this age, and approximately 34-40 pounds for the previous shoulder strap. Using the seat belt, I think this harness could also be labeled as an accessory to the seat belt; because when it is so threaded through the child cannot stand up and come out of their position. So many times they just slip out since the seat belt just goes across the lap and you turn around and the child is standing up. A very unsafe situation.

I have designed these harness so the child can't remove them, so they can grow with them, and so there is at least an inch on either side of the child waist band allowing for your seat belts and for growth.

The pink is a stronger webbing, and this was designed for blind children and hyperactive children and children who need extra strength. The regular harness in the summer material is the manufacturers. I have not started to manufacture the harness for the blind, as I have an improvement patent that is going in and it has lots of accessories on the harness for their needs.

I am going to try and write and find out the association where I could get my product tested for the high chair and my accessory belt in conjunction with the harness. If you know of any association on a federal level, please advise me. I also wanted to know if I could get approval from the council on new products

to get my harness tested, but I don't know how to do that. I am a nurse anesthetist and I work full time and also for the past two years part time in addition, but I have obtained 3 patents and have been trying to market and get manufacturing, etc. I am so tired and so broke, I just need help, assistance, or guidance. I am going to do a booth with the Governors Hwy. Safety in Asheville 14-16 of this month and I gave them harness (6) for door prices, but only for tethering children in crowds.

I do know this works for me and my grandson, but unfortunately they are in Fla. and I can't get their pictures with seat belts. I did some shading and drawings and they are attached, and tried to run a prototype of a shoulder strap and seat belt through the harness to show you how I threaded them. I just don't want to advertise wrong, or to do anything unsafe, or to be sued. I have just been selling these to two little stores and a lot of acquaintances.

I have given these little things I printed up, but I put the size 50 lbs. Truly it should be 35-40 lbs. Because the child starts to use these two devices by themselves at this age and weight. Age 3 1/2-4.

I also wanted you to look at my little paper that I will be including later for children as a service. My grandson got lost at Disneyworld 3 1/2 year ago for several hours and he had been wearing a wrist harness and he took it off. The lost and found was not for kids so I developed a safety emblem and an ID code and registration card for kids. Right now I am not using the club for record keeping as I can't afford it and I am using the information only as a warranty for the parent for the harness, but someday I would like to help the hwy. and local police to ID children, just from the harness number. My main aspect is to keep them from being lost, or keep them from getting hurt in cars in travel.

I would greatly appreciate any help you may give me or direction. Mr. Michael did not advise me to send the harness, but since I am the only employee of this business and I have to do everything, I just don't have the time to keep duplicating myself, and I certainly need help quickly, as I have told people this is something I do. I do not want to advise people wrongly, or harm anyone. Can you put these harness on dummies and try the seat belt and shoulder strap. Then, does this look like the harness can meet these standards you have an accessory to the existing seat belt and or shoulder strap for kids a certain age. What age, or weight do your standards allow children to use the two items mentioned without a car seat?

These items go over clothing so they do not have to be fire repellent as they are just like clothes. I always have one side cotton and the other water repellent or nylon to give strength and protection to chest area.

I am sure I must meet some sort of performance standards as a safety harness and for you as a safety belt accessory. The harness is better and safer for kids than any existing harness, and I have a patent readying for disabled kids of all kinds.

Isn't there anybody who can give me information on a grant or something as I have a very good patent for the existing seat belts, they are not right for children and I just can't afford to pay out anymore or work anymore to get this

accomplished. It would certainly help children in travel, we could also eliminate many devices that are sold in conjunction with safety in the high chair, and car to make children more comfortable and safer.

I have enclosed some information for your review, I have not yet sent Good Morning America any harness and I certainly did not want to go on the air and say anything about a seat belt and be incorrect. The second letter is from a woman who my sister sold a harness to when she was in London last year because the child kept leaving the parents side at the airport.

You see I am in a dilemma and I work on this stuff most of my off time from work. I also think having proof that this was indeed safe would greatly help me to market, not to mention the additional safety of kids; running out into moving cars, getting lost or missing; in cars to keep them in position, and even in high chairs in conjunction with little belts. We have a coloring booklet I am doing now and waiting for pictures to give children and parents instructions on safety and use of the harness. I would greatly appreciate any help you can give me, my phone number is on page one.

Any additional information you can think of I would appreciate. I am thanking you most sincerely.

P.S. On that sheet for the Safety Club and my club number, if and when I can ever afford to dot this as a service, how will law enforcement personnel know this is available, I still don't have a computer. Maybe this portion could be not for profit???

Attachments: - Body Safety Kids Club, Inc. Sales Brochure and Instruction/Direction Sheet - Diagram of Body Safety Kids Club Vest - Letter dated 3-2-93 from R. T. Sawyer, Director, Biopharm Limited to Liz Davies, Buying Director, MotherCare

(Text omitted.)

ID: 7721

Mr. Scott D. Boone
Van Conversions, Inc.
5255-Suite 16 Hull St.
Richmond, VA 23224

Dear Mr. Boone:

This responds to your letter of September 4, 1992 requesting information on standards applicable to vans you manufacture for use by day care centers. These vehicles have a 21 passenger capacity. During a September 16 phone conversation between Mary Versailles of my staff and Mr. George Croft of Van Conversions, Inc., Mr. Croft indicated that your company purchases incomplete vehicles manufactured by Ford (the E-250 chassis) and completes them into finished vehicles, by such operations as installing seats and seat belts. According to Mr. Croft, the completed vehicles have a gross vehicle weight rating (GVWR) of less than 10,000 pounds. Mr. Croft stated that your company was particularly interested in new requirements for lap/shoulder belts. I am pleased to have this opportunity to explain our law and regulations to you.

The National Traffic and Motor Vehicle Safety Act (the Safety Act; 15 U.S.C. 1381 et seq.) authorizes this agency to issue Federal motor vehicle safety standards applicable to new motor vehicles and new items of motor vehicle equipment. Section 108(a)(1)(A) of the Safety Act (15 U.S.C. 1397(a)(1)(A)) prohibits any person from manufacturing, introducing into commerce, selling, or importing any new motor vehicle or item of motor vehicle equipment unless the vehicle or equipment item is in conformity with all applicable safety standards. NHTSA, however, does not approve motor vehicles or motor vehicle equipment, nor do we endorse any commercial products. Instead, the Safety Act establishes a "self-certification" process under which each manufacturer is responsible for certifying that its products meet all applicable safety standards.

Your company would be considered a final-stage manufacturer under our regulations. As a final stage manufacturer, your company's certification responsibilities would depend on the information provided by the manufacturer of the incomplete vehicle. Under 49 CFR Part 568, the incomplete vehicle manufacturer must furnish your company with a document which states one of the following three things concerning the incomplete vehicle, for each of the safety standards:

1. The vehicle when completed will conform to the safety standard if no alterations are made to any identified components of the incomplete vehicle.

2. The vehicle when completed will conform to the safety standard if specific conditions are followed by the final-stage manufacturer.

3. Conformity with the safety standard is not substantially affected by the design of the incomplete vehicle, so the incomplete vehicle manufacturer makes no representation as to conformity with the standard.

Your company, as the final stage manufacturer, is required to certify that each vehicle you complete complies with all applicable safety standards. Such certifications may be based entirely upon the incomplete vehicle manufacturer's instructions and advice set forth in the document furnished with the incomplete vehicle.

The 21 passenger vehicles your company manufactures would be considered "buses" under NHTSA regulations. NHTSA defines a "bus" as "a motor vehicle with motive power, except a trailer, designed for carrying more than 10 persons." (49 CFR 571.3). In addition, your 21 passenger vehicles might be considered "school buses" if the day care center to which you sell the vehicle would be considered a school. A day care center would be considered a school if the function of the facility was primarily educational, rather than custodial. A "school bus" is defined as "a bus that is sold, or introduced in interstate commerce, for purposes that include carrying students to and from school or related events, but does not include a bus designed and sold for operation as a common carrier in urban transportation."

With respect to seat belts, Federal Motor Vehicle Safety Standard No. 208, Occupant Crash Protection, requires a bus, other than a school bus, with a GVWR of 10,000 pounds or less to have a lap/shoulder belt at every outboard seating position, and either a lap belt or a lap/shoulder belt at every other seating position. Standard No. 208 requires a school bus with a GVWR of 10,000 pounds or less to have a lap/shoulder belt at the driver's and right front passenger's seating positions, and either a lap belt or a lap/shoulder belt at every other seating position.

I am enclosing two publications for your information. The document titled "Federal Motor Vehicle Safety Standards and Regulations" will provide you with a summary description of the requirements of each standard, and a list of the types of vehicles to which each standard applies. The other document is a general information sheet for manufacturers which highlights the relevant Federal statutes and regulations, and explains how to obtain copies of the regulations.

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

Sincerely,

Paul Jackson Rice Chief Counsel

Enclosures

ref:568#208 d:9/8/92

ID: nht92-4.14

DATE: September 8, 1992

FROM: Paul Jackson Rice -- Chief Counsel, NHTSA

TO: Scott D. Boone -- Van Conversions, Inc.

TITLE: None

ATTACHMT: Attached to 01/01/92 (EST) letter from Scott Boone to Office of the Chief Counsel (OCC-7721)

TEXT:

This responds to your letter of September 4, 1992 requesting information on standards applicable to vans you manufacture for use by day care centers. These vehicles have a 21 passenger capacity. During a September 16 phone conversation between Mary Versailles of my staff and Mr. George Croft of Van conversions, Inc., Mr. Croft indicated that your company purchases incomplete vehicles manufactured by Ford (the E-250 chassis) and completes them into finished vehicles, by such operations as installing seats and seat belts. According to Mr. Croft, the completed vehicles have a gross vehicle weight rating (GVWR) of less than 10,000 pounds. Mr. Croft stated that your company was particularly interested in new requirements for lap/shoulder belts. I am pleased to have this opportunity to explain our law and regulations to you.

The National Traffic and Motor Vehicle Safety Act (the Safety Act; 15 U.S.C. 1381 et seq.) authorizes this agency to issue Federal motor vehicle safety standards applicable to new motor vehicles and new items of motor vehicle equipment. Section 108(a)(1)(A) of the Safety Act (15 U.S.C. 1397(a)(1)(A)) prohibits any person from manufacturing, introducing into commerce, selling, or importing any new motor vehicle or item of motor vehicle equipment unless the vehicle or equipment item is in conformity with all applicable safety standards. NHTSA, however, does not approve motor vehicles or motor vehicle equipment, nor do we endorse any commercial products. Instead, the Safety Act establishes a "self-certification" process under which each manufacturer is responsible for certifying that its products meet all applicable safety standards.

Your company would be considered a final-stage manufacturer under our regulations. As a final stage manufacturer, your company's certification responsibilities would depend on the information provided by the manufacturer of the incomplete vehicle. Under 49 CFR Part 568, the incomplete vehicle manufacturer must furnish your company with a document which states one of the following three things concerning the incomplete vehicle, for each of the safety standards:

1. The vehicle when completed will conform to the safety standard if no alterations are made to any identified components of the incomplete vehicle.

2. The vehicle when completed will conform to the safety standard if specific conditions are followed by the final-stage manufacturer.

3. Conformity with the safety standard is not substantially affected by the design of the incomplete vehicle, so the incomplete vehicle manufacturer makes no representation as to conformity with the standard.

Your company, as the final stage manufacturer, is required to certify that each vehicle you complete complies with all applicable safety standards. Such certifications may be based entirely upon the incomplete vehicle manufacturer's instructions and advice set forth in the document furnished with the incomplete vehicle.

The 21 passenger vehicles your company manufactures would be considered "buses" under NHTSA regulations. NHTSA defines a "bus" as "a motor vehicle with motive power, except a trailer, designed for carrying more than 10 persons." (49 CFR 571.3). In addition, your 21 passenger vehicles might be considered "school buses" if the day care center to which you sell the vehicle would be considered a school. A day care center would be considered a school if the function of the facility was primarily educational, rather than custodial. A "school bus" is defined as "a bus that is sold, or introduced in interstate commerce, for purposes that include carrying students to and from school or related events, but does not include a bus designed and sold for operation as a common carrier in urban transportation."

With respect to seat belts, Federal Motor Vehicle Safety Standard No. 208, Occupant Crash Protection, requires a bus, other than a school bus, with a GVWR of 10,000 pounds or less to have a lap/shoulder belt at every outboard seating position, and either a lap belt or a lap/shoulder belt at every other seating position. Standard No. 208 requires a school bus with a GVWR of 10,000 pounds or less to have a lap/shoulder belt at the driver's and right front passenger's seating positions, and either a lap belt or a lap/shoulder belt at every other seating position.

I am enclosing two publications for your information. The document titled "Federal Motor Vehicle Safety Standards and Regulations" will provide you with a summary description of the requirements of each standard, and a list of the types of vehicles to which each standard applies. The other document is a general information sheet for manufacturers which highlights the relevant Federal statutes and regulations, and explains how to obtain copies of the regulations.

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

ID: 11541MLV

Jerry G. Sullivan, PE
The Braun Corporation
P.O. Box 310
Winamac, IN 46996

Dear Mr. Sullivan:

This responds to your letter of January 30, 1996, requesting clarification of a recent amendment to the definition of "designated seating position" in 49 CFR '571.3. On March 24, 1995, the agency amended the definition of "designated seating position" to specify that a location intended for securement of an occupied wheelchair during vehicle operation will be regarded as four designated seating positions (60 FR 15504). You asked for clarification of whether this amendment applies in the following situations:

(1) Calculation of the payload of a vehicle.

(2) Classification of a vehicle as a school bus vs. multipurpose passenger vehicle (mpv).

(3) Classification of a vehicle as a bus vs. mpv.

As amended, the definition of designated seating position states, in pertinent part:

* * * For the sole purpose of determining the classification of any vehicle sold or introduced into interstate commerce for purposes that include carrying students to and from school or related events, any location in such vehicle intended for securement of an occupied wheelchair during vehicle operation shall be regarded as four designated seating positions.

According to the above-quoted language, a wheelchair position is regarded as four designated seating positions only for situation (2) above. If a vehicle is not intended for transportation of students, the determination of whether the vehicle is a bus or an mpv is done regarding any wheelchair locations as a single designated seating position. The calculation of payload or gross vehicle weight rating for any vehicle, including school buses, is done regarding any wheelchair locations as a single designated seating position.

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:571.3 d:2/22/96

ID: nht72-3.32

DATE: 05/08/72

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Stylar Industries Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of March 22, 1972, on the subject of the application of Motor Vehicle Safety Standard No. 207 to the type of swivelling seat manufactured by your company.

We understand from your letter that you are concerned about the type of swivelling seat that is not continuously fastened to its base and that can therefore come loose in a rollover accident. To avoid this problem, you have designed your seat with a stud bolt that links the seat to its base regardless of the amount of rotation. Your question to us is whether removal of the stud bolt would cause the seat not to conform to Standard 207.

The answer to your question depends in part on whether the seat without the bolt would be able to meet the applicable strength requirements of the standard. Removal of the stud belt would not, in itself, cause the seat not to conform to the standard. The seat would conform to S4.3 if the seat were to lock itself by means other than the bolt when returned to the forward facing position.

ID: nht87-3.48

TYPE: INTERPRETATION-NHTSA

DATE: 12/14/87

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Robert C. Geschwender -- Lin-Mart

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. Robert C. Geschwender Lin-Mart P.0. Box 82431 Lincoln, NE 68501-2431

This responds to your November 3, 1987 letter to me asking whether any of our regulations apply to the "Head Hugger," an aftermarket product you have designed for use in motor vehicles. The Head Hugger is a head pillow that attaches to a head restraint a nd is designed to support a passenger's head and neck when he or she is seated in a reclined position. I hope the following information is helpful.

The National Highway Traffic Safety Administration (NHTSA) has the authority to regulate the manufacture and sale of new motor vehicles and items of motor vehicle equipment. Although NHTSA has issued motor vehicle safety standards for certain types of mo tor vehicle equipment, we have no standard directly applicable to the Head Hugger. Thus, the manufacture and sale of your aftermarket product to a vehicle owner for installation in his or her vehicle would not be affected by the requirements of any Feder al motor vehicle safety standard.

However, if the Head Hugger will be installed in new or used vehicles by a commercial business, then S108(a)(2)(A) of the National Traffic and Motor Vehicle Safety Act could affect your product in certain circumstances. That section of the Act requires m anufactures, distributors, dealers and motor vehicle repair businesses to ensure that they do not knowingly render inoperative any device or element of design installed on or in a motor vehicle in compliance with an applicable Federal safety standard. These commercial entities could sell your product, but could not install it if the installation would negatively affect the vehicle's compliance with our standards for occupant protection in interior impacts (Standard No. 201), head restraints (Standard No. 202) of flammability resistance (St andard No. 302). In the first instance, it would be the responsibility of these entities to determine whether there is any possibility of such an effect.

Again, however, the prohibitions of S108(a)(2)(A) do not apply to the actions of a vehicle owner in adding to or otherwise modifying his or her vehicle. Thus, a vehicle owner would not violate the Act by installing the Head Hugger, even if doing so would negatively affect some safety feature in his or her vehicle.

There is an additional aspect of the Act of which you should be aware. The act requires the recall and remedy of motor vehicles and motor vehicle equipment determined to contain a defect relating to motor vehicle safety. If you or NHTSA determine that th e Head Hugger contains such a defect, you must recall and repair or replace the item without charge to the purchaser.

We have enclosed a copy of the act, and an information sheet describing how you can obtain copies or our motor vehicle safety standards and any other NHTSA regulation. Please contact us if we can be of further assistance.

Sincerely,

Erika Z. Jones Chief Counsel

Enclosure

3-11-87

Erika Z. Jones Chief Counsel National Highway Traffic Administration 400 Seventh Street, S.W.- Room 5219

Dear Ms. Jones:

I wish to establish if there is any legal requirement on a new "after market" automotive product which I have designed.

The item is an auto head pillow for use in the reclined seat position.

The item named Head Hugger is upholstered with polyester and polyester and cotton blend fabrics. The filling is fire retardant polyurethane foam block.

If this product manufactured as an after market item falls under any federal regulations, please supply copies of acceptable regulations. Thank you.

Yours Truly,

Robert C. Geschwender

cc: Senator J.J. Exon

HEAD HUGGER TM

(Recliner AUTO PILLOW)

The head hugger is designed to be used in conjunction with reclined auto seats. Although reclined auto seats are offered on many cars the head rests are primarily as a head restraint in the event of rear impact. Most head rests are designed to have a 2 inch clearance between the rest and the occupants head so as not to interfere with head movement. This, however, provides inadequate support in a reclined position.

Head Hugger supports not only the head but also the neck from road jarring. The unique saddle shape of the Head Hugger prevents the resting head from sliding to far too either side. Head Hugger's tapered shape assures a smooth transition betwe en upper seat and the head support.

The unit can be easily installed in any car with a head rest by use of the two velcro straps which are attached to the hood on the back of the Head Hugger. The two strap attachment allows the Head Hugger to be used on either seat including those with s eat belts attached to the head rests.

A trial of the Head Hugger will convince any person of its comfort.

ID: nht95-1.56

TYPE: INTERPRETATION-NHTSA

DATE: February 7, 1995

FROM: Philip R. Recht -- Chief Counsel, NHTSA

TO: Thomas J. Leffler -- Developmental Shop Manager, Findlay Industries, Inc.

TITLE: None

ATTACHMT: ATTACHED TO 11/8/94 LETTER FROM THOMAS J. LEFFLER TO PHILIP RECHT

TEXT: Dear Mr. Leffler:

This responds to your letter of November 8, 1994, asking whether S4.3 of Standard No. 207, Seating Systems, requires a self-locking device to restrain the seat cushion of a particular seat design in the down position. The seat "has a storage box below t he seat cushion frame. To access the storage space, the seat cushion pivots up to allow entry into the box." If a self-locking device is required, you asked whether static or dynamic testing is required for the device.

Section S4.3 of Standard No. 207 requires "a hinged or folding occupant seat or occupant seat back" to be equipped with a self-locking restraining device. NHTSA does not consider the words "occupant seat or occupant seat back" to refer to the seat cushio n alone, and therefore a restraining device for the cushion alone is not required.

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

ID: 10498

Mr. Thomas J. Leffler
Developmental Shop Manager
Findlay Industries, Inc.
1957 Crooks Road
Troy, MI 48084

Dear Mr. Leffler:

This responds to your letter of November 8, 1994, asking whether S4.3 of Standard No. 207, Seating Systems, requires a self-locking device to restrain the seat cushion of a particular seat design in the down position. The seat "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." If a self-locking device is required, you asked whether static or dynamic testing is required for the device.

Section S4.3 of Standard No. 207 requires "a hinged or folding occupant seat or occupant seat back" to be equipped with a self-locking restraining device. NHTSA does not consider the words "occupant seat or occupant seat back" to refer to the seat cushion alone, and therefore a restraining device for the cushion alone is not required.

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

Sincerely,

Philip R. Recht Chief Counsel

ref:207 d:2/7/95

ID: nht91-6.13

DATE: October 3, 1991

FROM: Darrell E. Lischynski -- P.Eng., Project Manager, Energy and Processing, Prairie Agricultural Machinery Institute

TO: Mary Versailles -- Office of the Chief Counsel, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 12-4-91 from Paul Jackson Rice to Darrell E. Lischynski (A38; Std. 207; Std. 208; Std. 209; Std. 210; VSA 108(a)(2)(A))

TEXT:

I am writing this letter on behalf of Calmar Industries Inc. of Outlook, Saskatchewan, who manufacture a Seat Lift Kit for Ford Supercab trucks, as described in the attached product literature. Calmar wishes to market their Lift Kit in USA, and wants to be sure that they have met all required safety regulations.

The Calmar Seat Lift Kit is an attachment to raise the rear bench seat in Ford Supercab trucks. The kit does not alter the factory seat, and uses the factory seat belts. However, the seat mounts are changed, and an extension is provided to raise the seat belt attachment point.

PAMI is an independent engineering organization funded by the provincial governments that has tested the Calmar Seat Lift Kit according to Canadian and American safety standards 207 (seating systems) and 210 (Seat Belt Anchorages) as described in the attached certificates. If these are all of the safety standards that this kit must meet, Calmar would appreciate a letter from yourself stating so. If the kit must be tested to meet other standards, please inform Denis Tofin of Calmar Industries, or myself, so that tests can be initiated.

Thank you for your time.