Interpretation ID: nht78-3.11

DATE: 10/06/78

FROM: AUTHOR UNAVAILABLE; J. J. Levin, Jr.; NHTSA

TO: Southwest Research Institute

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your June 27, 1978, letter concerning the requirements of Safety Standard No. 207 as they would apply to pedestal seat assemblies for use in van vehicles. You ask whether your test methodology is consistent with the requirements of the standard and whether the pedestal base is considered part of the seat assembly.

As you know, the agency does not approve a manufacturer's test methods. A manufacturer must exercise due care to ascertain that his product is in compliance with all applicable motor vehicle safety standards and regulations. While your test methods appear to be reasonable, the agency will test seats in the vehicle rather than on a surrogate test frame. You must exercise due care to assure that your simulated test is a true determination whether the seats would comply with the standard when tested as provided in that standard. (The vehicle manufacturer is, of course, responsible for compliance with Standard 207.)

Regarding your second question, the pedestal base would be considered part of the seat assembly for purposes of Standard 207. This means that the agency would test the entire assembly by applying a force of 20 times the combined weight of the seat and the pedestal, contrary to your simulated test procedure of using only the weight of the seat frame and adjuster, without the pedestal base attached.

Finally, the force requirements of Safety Standard No. 210, Seat Belt Assembly Anchorages, (5,000 pounds) are applied simultaneously with the force requirements in Standard No. 207, if the anchorages are connected to the vehicle seat, to the pedestal, or to the pedestal base.

Please contact this office if you have any further questions, and please excuse the delay in this response.

SINCERELY,

SOUTHWEST RESEARCH INSTITUTE

DEPARTMENT OF STRUCTURAL SYSTEMS AND FIRE TECHNOLOGY

June 27, 1978

National Highway Traffic Safety Administration Office of Chief Counsel

Attention: Chief Counsel

Subject: Interpretation of FMVSS 207/210 Load Application to Van Seating Assemblies Gentlemen:

SwRI is currently performing qualification testing of van seating systems for commercial seat assembly manufacturers. The purpose of these tests has been to provide test data which demonstrates that the seat assembly appears to qualify to the requirements of FMVSS 207. These seat assemblies consist of a seat frame, seat adjuster tracks (if applicable), and pedestal base. Since this entire assembly is manufactured as a separate component for sale to van manufacturers, SwRI performs the tests and reports the results with the understanding that the portion of the assembly above the pedestal base does/does not appear to qualify to the load/time profile requirements of the Standard. In addition, SwRI insures that the test conditions which are not consistent with the requirements of FMVSS 207 are delineated, which are:

1. The assembly is tested on a rigid test frame (not in a vehicle).

2. SwRI utilizes available fasteners to secure the pedestal base to the test fixture (since OEM fasteners are not available).

3. Satisfactory test results are reported which indicate that only the seat structure and fasteners attaching the seat frame to the adjuster track and pedestal base appear to qualify to the requirements of FMVSS 207.

4. The fore/aft CG loads are calculated based on the seat frame and adjuster weight without the pedestal base attached.

SwRI would like an interpretation to determine if this methodology is consistent with the requirements of FMVSS 207.

SwRI has recently received a "barrel" van seat assembly which is constructed as illustrated in the attached sketch. This assembly has seat belt anchorage holes in the gussetted plate. The seat frame is attached to the gussetted plate which is secured to the pedestal base. SwRI would like an interpretation on the correct load application to this assembly by responding to the following:

* Is the load applied as required in FMVSS 207 -- i.e. Forward CG load = 20 x seat assembly weight + 2500 lbs. for each anchorage?

or

* Is the FMVSS 210 load (5000 lbs.) applied separately?

It appears the key question with these seat assemblies is, "Is the pedestal base considered a part of the seat assembly as it applies to the FMVSS 207 requirements?"

Your prompt response to this request will be appreciated as SwRI has a sponsor awaiting test results.

Charles J. Kerr Research Engineer

cc: VINCE QUARLES SEAT STRUCTURE TUBING

FIBERBOARD

PEDESTAL BASE

PEDESTAL ANCHORAGE POINTS

GUSSETTED PLATE

SEAT BELT ANCHORAGE POINTS

"BARREL" VAN SEAT ASSEMBLY

(Graphics omitted)