Interpretation ID: nht92-6.14

DATE: June 8, 1992

FROM: Michael F. Hecker -- Micho Industries

TO: Paul Jackson Rice -- Chief Counsel, NHTSA

COPYEE: M. Dunn; R. Rogers

TITLE: Re: R-BAR Passenger Restraint System

ATTACHMT: Attached to letter dated 7/14/92 from Paul J. Rice to Michael F. Hecker (A39; Std. 222)

TEXT:

I wish to thank you for your response to my letter of March 31, 1992.

We understand that the R-BAR, once installed on the seatback, becomes part of the seatback and therefore is subject to the test requirements of F.M.V.S.S. #222. Further, in determining the proper test procedures for this device, in accordance with the stated regulations (CFR 49 571.222 S6.4.) and including Laboratory Procedures #TP-222-01 (re: B. Pretest Procedure, step #6), we understand that since the R-BAR is part of the seatback, and adjustable, that the testing procedures are to be done in its most upright position.

Please advise us if this is a proper interpretation of this (S6.4) regulation.

Once again, thank you in advance for consideration in this matter.