Interpretation ID: nht93-6.19

DATE: August 18, 1993

FROM: Tom DeLapp -- Executive Coach Builders, Inc.

TO: Chief Council -- NHTSA

TITLE: F.M.V.S.S. #207

ATTACHMT: Attached to letter dated 10/1/93 Est. from John Womack to Tom DeLapp (A41; Std. 207)

TEXT:

As a manufacturer of quality limousines we expect to meet or exceed any safety regulation which would affect our vehicles. To this end, we request an interpretation to Federal Motor Vehicle Safety Standard (F.M.V.S.S.) = 207, specifically the section addressing folding or hinged seats.

During and after production of 1993 Ford/Lincoln Town Cars, access to the area rearward of the front seat is limited due to the inclusion of a privacy panel installed to separate the passenger compartment from the drivers compartment. To allow ourselves and our customers access to the area between the front of the panel and the back of the front seat (containing auxiliary fuse panels and relays), we wish to modify the hinge assembly controlling forward and reclining movement of the seat. As constructed by Ford/Lincoln, the seat hinge is limited in it's forward movement by a metal pin in the hinge assembly. By removal of the pin, the seat would articulate forward to a greater degree, thereby providing access to the area in question. This modification is as provided on two door vehicles to allow passengers access to the rear seating.

No change or modification of the O.E.M. recliner latch is performed by our company. The recliner latch provides for a self locking mechanism (and release) for the articulation of the seat back.

Research by myself of the F.M.V.S.S. standards does not reveal a prohibition to removal of the limiting pin or a forward travel limit to the seat back. Additionally, a phone conversation with Clark Harper of the F.M.V.S.S. staff on 8-17-93 failed to locate a prohibition to this modification.

Please address this matter at your earliest convenience. Should you require further information or engineer drawings, please contact me by phone or FAX.

Phone (417) 831 3535 FAX (417) 831 0834