Interpretation ID: nht95-1.25

TYPE: INTERPRETATION-NHTSA

DATE: January 13, 1995 EST

FROM: Philip R. Recht -- Chief Counsel, NHTSA

TO: Melinda Dresser -- Manager Contracts/Transportation, Carlin Manufacturing, Inc.

TITLE: NONE

ATTACHMT: Attached to 11/28/94 letter from Melinda Dresser to Mary Versailles

TEXT: Dear Ms. Dresser:

This responds to your letter of November 28, 1994, concerning seats with swivel bases. You noted that, in a November 25, 1992 letter to Ms. Frances Parton, we stated that there is no express prohibition in Federal law against installing a seat with a sw ivel base. You asked for a "current written determination" of that issue. This letter confirms that there is still no express prohibition in Federal law against installing a seat with a swivel base.

As explained in our November 1992 letter, the National Highway Traffic Safety Administration is authorized to issue Federal Motor Vehicle Safety Standards for new motor vehicles and new items of motor vehicle equipment (49 U.S.C. @ 30101 et seq.). Manuf acturers are required to certify that their products meet all applicable safety standards.

A manufacturer must consider three safety standards if a seat with a swivel base is installed in a vehicle: Standard No. 207, Seating Systems, Standard No. 208, Occupant Crash Protection, and Standard No. 210, Seat Belt Assembly Anchorages. Standard No. 207 establishes strength and other performance requirements for vehicle seats. Standard No. 208 sets forth requirements for occupant protection at the various seating positions in vehicles. Standard No. 210 establishes strength and location requirement s for seat belt anchorages. Nothing in these standards expressly prohibits a seat with a swivel base. Instead, a seat with a swivel base must comply with the same standards as other seats.

I hope you find this information helpful. If you have any other questions, please contact Mary Versailles of my staff at this address or by phone at (202) 366-2992.