Interpretation ID: nht89-3.38

TYPE: Interpretation-NHTSA

DATE: November 14, 1989

FROM: Vaughn Crawley -- Vice President, Monitor Manufacturing Co.

TO: Steven Wood -- Acting Chief Counsel, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 8-15-90 to V. Crawley from P. J. Rice; (A36; VSA 108(b)(2)

TEXT:

I am writing at the recommendation of Marvin Shaw of your Department, to whom I was referred by Mr. Jettner of the Crash Worthiness Engineering Branch of DOT.

My question is, that if necessary to respond to a certification review of the National Highway Traffic Safety Administration, and in order to support certification that the vehicles meet the requirements of FMVSS #207, Seating System and #210, Seat Belt Assembly Anchorages; would test reports and engineering analysis of the individual components of the seating system tested independently, one from the other, meet the require ments of the law? For instance, in a van conversion, if the pedestal, the seat , and the seat belts are supplied by different manufacturers and have been tested and supported by test reports and engineering analysis to conform to the requirements of FMVSS #207 and #210. Would these documents be adequate as a basis of certification of the seating system, or would the components have to be combined together and re-tested in order to comply with the request for certification. Your prompt response would be appreciated.