FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA
TO: Mr. Scott Muirhead
TITLE: FMVSS INTERPRETATION
TEXT: Thank you for your letter of August 2, 1986 to William Smith of this agency, requesting information on which of the agency's regulations would apply to a new product you are considering as an item of original and aftermarket equipment. Your letter was referred to my office for reply. You described the product as a cross-bed seat for use in pickup trucks. The seat would be made of plastic and supported by a fabricated metal frame and be mounted in the front of the truck bed facing the rear. According to your description, the seat would have safety belts. The following discussion explains the application of our regulations to your potential product.
Since your potential product would be used as a seating position in a motor vehicle while the vehicle is in motion, each occupant position on the seat would be considered a designated seating position by the agency. If your product is installed as an item of original equipment on a truck before its sale to its first purchaser, the designated seating positions must conform to the requirements of Standard No. 207, Seating Systems; Standard No. 208, Crash Protection; Standard No. 209, Seat Belt Assemblies; and Standard No. 210, Seat Belt Assembly Anchorages. I have enclosed an information sheet explaining how you can obtain copies of our safety standards.
If your product is sold as an item of aftermarket equipment to be installed by a vehicle owner, it would not be required to comply with Standard Nos. 207, 208, and 210. However, the safety belts provided with the seat would have to comply with Standard No. 209.
Finally, as a manufacturer of an item of motor vehicle equipment, you have a responsibility under section 151 et seq. of the National Traffic and Motor Vehicle Safety Act to conduct a notification and remedy campaign if you or the agency determines that your product contains a safety-related defect or does not comply with an applicable standard. A copy of an information sheet briefly describing those responsibilities is enclosed.
If you have any further questions, please let me know.
August 22, 1986
MR. SMITH -- Office of Vehicle Safety Standards, NHTSA Dear Sir:
After having reviewed the various motor vehicle safety standards sent to my attention from your good office. I have concluded that our particular Seating System falls outside the standards regulating inboard multi-purpose passenger vehicle seating.
I am therefore enclosing rough sketches of the seating system our company is developing for both an original and after equipment market. I trust these sketches will enable you to identify any Federal Safety Standards which may be or become applicable to a seating system of this nature.
Thanking you in advance for your attention and kind consideration, I am
Scott Muirhead -- New Project Manager