Interpretation ID: nht92-6.30

DATE: May 28, 1992

FROM: Christian Hammarskjold -- Vice President, USSC Group, Inc.

TO: Paul Jackson Rice -- Chief Council, NHTSA

COPYEE: Dan Cohen -- NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 8/10/92 from Paul J. Rice (signed by John Womack) to Christian Hammarskjold (A39; Std. 207; Std. 208); Also attached to letter dated 5/28/92 from Christian Hammarskjold to Paul J. Rice

TEXT:

I have spoken with Mr. Cohen who asked me to direct my questions to you in writing.

USSC is a supplier of suspension seats for drivers to transit buses. Our customers, SCRTD in Los Angeles, has asked us to develop a system whereby our suspension seats can tilt from side-to-side. This is meant to compensate for the slanted roads in LA that facilitate water run off.

We are, of course, aware of 207/210 and do not believe that tilt system will meet the performance requirements. In addition, USSC is concerned that there are not applicable FMVSS requirements that address a side-to-side strength requirements. 207/210 requires a pull from the front of the seat. What happens if there is a side impact on a suspension seat that has a ball and socket joint. Are there any applicable performance requirements that may apply to such a system.

We request an answer by mail or fax by June 15, 1992. This will allow us enough time to respond to SCRTD's June 19th deadline.

If you have any questions, please call.

(Drawings omitted)