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Federal Motor Vehicle Safety Standards Seating Systems; Pedestal Seats

American Government Special Collections Reference Desk

American Government Topics:  National Highway Traffic Safety Administration, Federal Motor Vehicle Safety Standards

Federal Motor Vehicle Safety Standards Seating Systems; Pedestal Seats

Christopher A. Hart
Federal Register
July 21, 1994

[Federal Register: July 21, 1994]


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DEPARTMENT OF TRANSPORTATION

National Highway Traffic Safety Administration

49 CFR Part 571

[Docket No. 90-16; Notice 03]
RIN 2127-AD09

 
Federal Motor Vehicle Safety Standards Seating Systems; Pedestal 
Seats

AGENCY: National Highway Traffic Safety Administration (NHTSA), DOT.

ACTION: Final rule.

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SUMMARY: This notice amends Standard 207, Seating Systems, to establish 
a more appropriate test procedure for pedestal seats. Manufacturers of 
most pedestal seats will have a choice between the current test 
procedure or the new test procedure. The current test procedure applies 
a single load through the center of gravity (cg) of the entire seat. 
The new test procedure applies two separate loads, one through the cg 
of the portion of the seat above the adjuster and the other through the 
cg of the pedestal. This rule is a response to manufacturer concerns 
that the current Standard No. 207 test procedure imposes excessive 
loads on the adjuster for pedestal seats when the cg of the seat is 
located above the seat adjuster. (The adjuster is typically located 
between the pedestal and the seat.) Manufacturers believed that the 
current test procedure is inappropriate for seats whose cg is located 
above the adjuster because a portion of the load applied to the seat, 
and therefore imposed on the adjuster, represents the weight of the 
pedestal. In a real crash, only the weight of the seat that is above 
the adjuster would be imposed on the adjuster.

DATES: Effective Date: The amendments made in this rule are effective 
October 19, 1994.
    Petition Date: Any petitions for reconsideration must be received 
by NHTSA no later than August 22, 1994.

ADDRESSES: Any petitions for reconsideration should refer to the docket 
and notice number of this notice and be submitted to: Administrator, 
National Highway Traffic Safety Administration, Room 5109, 400 Seventh 
Street, SW., Washington, DC., 20590.

FOR FURTHER INFORMATION CONTACT: Dr. William J.J. Liu, Office of 
Vehicle Safety Standards, NRM-12, National Highway Traffic Safety 
Administration, 400 Seventh St., SW., Washington, DC., 20590. 
Telephone: (202) 366-2264.

SUPPLEMENTARY INFORMATION: On August 14, 1990, NHTSA published a notice 
of proposed rulemaking (NPRM) to amend Standard 207, Seating Systems, 
establish a more appropriate test procedure for pedestal seats (55 FR 
33141). Under the proposed test procedure, the pedestal and the seat 
portion of a pedestal seat would each be separately, but 
simultaneously, loaded. The NPRM proposed definitions for a ``pedestal 
seat,'' and parts thereof, to differentiate such seats from other 
seating systems.
    March 8, 1993, NHTSA published a supplemental notice of proposed 
rulemaking (SNPRM) for the same rulemaking (58 FR 12921). The SNPRM and 
the 1990 NPRM differed in two principal respects. The first concerned 
the definition of ``pedestal seat.'' Instead of attempting to define 
and differentiate different parts of a pedestal seat from one another, 
as was done in the NPRM, the SNPRM simply divided pedestal seats into 
two portions, that above the adjuster and that below the adjuster. The 
second difference concerned whether the new test procedure would 
replace the current procedure or become an alternative to it. The new 
test procedure proposed in the SNPRM was virtually identical to that 
proposed in the NPRM, except that the SNPRM gave manufacturers the 
option of using either the current single load procedure or the new 
dual load test procedure for testing most pedestal seats.
    The agency received six comments concerning the March 1993 SNPRM. 
In general, the commenters supported the SNPRM. All of the comments 
were considered when formulating this final rule, and the most 
significant comments are addressed below.

Definitions

    The SNPRM proposed a new definition for ``seat adjuster'' as 
follows:

    ``Seat adjuster'' means the part of the seat that allows the 
seat bench and back to move forward and rearward, and/or to rotate 
around a vertical axis, including any fixed portion, such as a seat 
track. The term also means the uppermost seat adjuster in the case 
of a seat equipped with seat adjusters at different levels.

    AM General Corp. (AM General), Chrysler Corp. (Chrysler), and Volvo 
GM Heavy Truck Corp. (Volvo) commented on the proposed definition. AM 
General and Chrysler commented that the proposed definition excluded 
nonadjustable pedestal seats and asked that the proposed test procedure 
also apply to that type of seat.
    NHTSA agrees with AM General and Chrysler that the amendments 
proposed in the SNPRM apply only to adjustable pedestal seats. The 
focus of this rulemaking has always been manufacturer concerns that the 
current Standard No. 207 test procedure imposes excessive loads placed 
on the adjusters for pedestal seats. The current test procedure 
requires a single load to be applied through the center of gravity (cg) 
of the entire seat. If the cg of a pedestal seat lies at or above the 
adjuster, the test procedure places the load of the entire seat, 
including the pedestal, on the adjuster. However, in a real-world 
crash, the adjuster would not have loads imposed on it from the 
pedestal. NHTSA does not believe the same concerns apply to non-
adjustable pedestal seats. In addition, NHTSA notes that extending this 
rule to non-adjustable pedestal seats would be outside the scope of 
notice of this rulemaking.

    Volvo stated that the:

    (s)uspension seats in heavy trucks also include a fore and aft 
slide device which allows the seat to ``float'' and absorb the pitch 
moment generated by rough roads or uneven loading.

    Volvo asked that the definition be changed to clarify that the 
adjuster is the part of the seat that provides forward and rearward 
positioning of the seat, rather than a part of the seat which allows 
the seat to move while the vehicle is in motion. NHTSA agrees that the 
Volvo change clarifies the definition and has adopted the change as 
suggested.

Test Procedure

Adjustment Position (S5.1.1(a))

    The test procedure proposed in the SNPRM specified that, if the 
height of the seat were adjustable, the loads were to be applied when 
the seat was in its highest adjustment position. Volvo stated that, 
since the seat belts of many heavy trucks are mounted on the seat, the 
compliance tests for Standard No. 207 and Standard No. 210, Seat Belt 
Assembly Anchorages, are regularly conducted simultaneously. Volvo 
stated that the requirement that the seat be adjusted to its highest 
adjustment position conflicted with Standard No. 210, which

    requires some loading conditions to be applied with the seat in 
the rearmost position and some of the belt anchors in the midpoint 
of any adjustment range. The Administration has previously 
interpreted NHTSA TP 210 for suspension seats to be in the vertical 
mid ride position.

    The Recreation Vehicle Industry Association (RVIA), stated that the 
Standard No. 207 ``test procedures have long stated that such a seat is 
to be tested at its midpoint adjustment.''
    Neither the current Standard No. 207 nor Standard No. 210 have 
height adjustment requirements for testing adjustable seats. However, 
the current version of the Laboratory Test Procedure for Standard No. 
207 specifies the highest point adjustment (P. 25, Figure 6, ``Forward 
and Aft Loads on Seat Frame with Seat Belts Attached to Seat,'' TP-207-
09, January 18, 1992.) NHTSA would like to emphasize that the 
Laboratory Test Procedures are provided to contracted laboratories as 
guidelines for conducting compliance tests, and do not limit the 
requirements of the applicable Federal motor vehicle safety standards. 
Since Standard No. 207 does not limit the adjustment position, the seat 
is required to meet the current requirement in all adjustment 
positions, and the fact that a test procedure specifies a specific 
adjustment position does not limit this requirement.
    Section S4.3.2 of Standard No. 210 specifies that the seat is to be 
adjusted ``to its full rearward and downward position * * *'' However, 
this section is related to the seat belt angle location requirements, 
and does not necessarily apply to load testing.
    None of the commenters offered a convincing argument as to why 
NHTSA should not specify the adjustment position. Since NHTSA believes 
that having to meet Standard No. 207 in the proposed highest adjustment 
position would necessitate designing a stronger, safer seat than having 
to meet the standard in another adjustment position, NHTSA has retained 
the procedure as proposed.

Horizontal Plane (S5.1.1(a)(1))

    Chrysler commented that the language of S5.1.1(a)(1), ``* * * 
horizontal plane tangent to the lowest surface of the seat adjuster * * 
*,'' did not reflect some of the seat adjuster designs on its vehicles. 
Chrysler stated that the lowest mounting surface on some designs did 
not lie in a horizontal plane, and the forward/rearward motion of some 
designs was not linear. For this reason, Chrysler suggested that the 
word ``horizontal'' be deleted from this section.
    NHTSA agrees with Chrysler it is not possible to specify the 
horizontal plane tangent to the lowest surface of the seat as the 
tangent to the lowest surface of some seat adjusters will not be 
horizontal. The purpose of S5.1.1(a)(1) is to define whether the load 
is in (or above) any part of the seat adjuster, which will allow 
manufacturers the option of using either test procedure. Since the 
applied test load is horizontal and the tangent plane to the lowest 
surface of the adjuster may not be horizontal for all possible cases, 
the word ``tangent'' is deleted.
    As explained above, NHTSA is amending Standard No. 207 because the 
application of a single load imposes an unnatural load on the seat 
adjuster if the cg is at or above the adjuster. Therefore, NHTSA is 
amending S5.1.1(a)(1) to allow manufacturers the option of applying 
either one or two loads whenever the horizontal plane containing the cg 
either contacts any portion of the seat adjuster or is above the seat 
adjuster. Section S5.1.1(a)(3) has also changed to reflect the change 
in S5.1.1(a)(1).

Not Physically Possible

    NHTSA proposed to allow manufacturers a choice between the current 
test procedure and the new test procedure whenever the cg of the seat 
was above the adjuster unless it was ``not physically possible'' to use 
the dual load test procedure. Volvo objected to the language in 
proposed S5.1.1(a)(2) requiring manufacturers to use the single load 
test procedure when it is ``not physically possible'' to use the dual 
load test procedure since this limited a manufacturer's choice.
    Based on the testing done by the agency, the pedestal must be 
approximately 4 inches high for it to be physically possible to use the 
test device. Since the agency no longer defines a pedestal seat in 
relation to the height of the pedestal, NHTSA believes that this 
limitation is necessary. If NHTSA did not include this limitation, the 
agency might be precluded from conducting a compliance test in the case 
of a pedestal seat whose pedestal is too short to accommodate the test 
device.

Specification of Dual Load Procedure for Some Pedestal Seats

    The SNPRM proposed S5.1.1(a)(3) specified the use of the new dual 
load test procedure whenever the cg of the seat ``is located below the 
horizontal plane tangent to the lowest surface of the seat adjuster.'' 
Ford Motor Co. (Ford) stated that it believed that this section should 
specify the use of the single load test procedure instead of the dual 
load test procedure. It provided no explanation for its belief.
    Ford's suggestion is inappropriate. Specifying the use of the dual 
load test procedure when the cg is below the seat adjuster ensures that 
test loads will be applied to both the pedestal and the seat. If a 
single load were applied, only the strength of the attachment of the 
pedestal to the vehicle, and not the strength of the attachment of the 
seat to the pedestal, would be tested.

Clarification of S5.1.1(a)

    NHTSA has made various minor changes to S5.1.1(a) for the purpose 
of clarifying and simplifying the language.

Effective Date

    The SNPRM proposed that the effective date for the option to use 
either the single or dual load test procedure be 90 days after 
publication of the final rule. RVIA urged NHTSA to adopt an effective 
date at least one year following publication of the final rule. RVIA 
stated that the proposed effective date ``does not provide sufficient 
lead time for manufacturers to deplete existing stock, conduct 
additional tests under either procedure, and make any necessary design 
or structural modifications.
    NHTSA disagrees with RVIA's reasoning. The only type of seat for 
which modifications might be necessary are seats whose cg is below 
their seat adjuster. All other seats either will continue to be 
required to be certified to the current test procedure or will have the 
option of certifying to the current test procedure, and therefore, will 
not require modification. NHTSA is not aware of any current seat 
designs whose cgs are below their adjusters. Therefore, NHTSA continues 
to believe the 90 day leadtime is sufficient.

Rulemaking Analyses and Notices

EXECUTIVE ORDER 12866 AND DOT REGULATORY POLICIES AND PROCEDURES: NHTSA 
has considered the impact of this rulemaking action under E.O. 12866 
and the Department of Transportation's regulatory policies and 
procedures. This rulemaking document was not reviewed under E.O. 12866, 
``Regulatory Planning and Review.'' This action has been determined to 
be not ``significant'' under the Department of Transportation's 
regulatory policies and procedures.
    This action will have no economic impacts other than a one-time 
cost related to the test fixture, for those manufacturers choosing the 
new procedure. In particular, they would have to add pneumatic or 
hydraulic rams to their test set-up. It is estimated that there would 
be a one-time set-up cost of $2,500. The test procedure would not 
require any design, retooling, or assembly changes.

REGULATORY FLEXIBILITY ACT: NHTSA has also considered the impacts of 
this final rule under the Regulatory Flexibility Act. I hereby certify 
that this rule will not have a significant economic impact on a 
substantial number of small entities. Vehicle manufacturers typically 
would not qualify as small entities. While some manufacturers of 
pedestal seats and seat belt attachments may be small entities, for the 
reasons stated above, NHTSA believes this final rule would not 
significantly affect them. The final rule will not affect the costs of 
pedestal seats, since the new procedure is optional. Because of this, 
small organizations and governmental units that purchase vehicles with 
pedestal seats should not be affected by this final rule.

PAPERWORK REDUCTION ACT: In accordance with the Paperwork Reduction Act 
of 1980 (P.L. 96-511), there are no requirements for information 
collection associated with this final rule.

NATIONAL ENVIRONMENTAL POLICY ACT: NHTSA has also analyzed this final 
rule under the National Environmental Policy Act and determined that it 
will not have a significant impact on the human environment.

EXECUTIVE ORDER 12612 (FEDERALISM): Finally, NHTSA has analyzed this 
rule in accordance with the principles and criteria contained in E.O. 
12612, and has determined that this rule will not have significant 
federalism implications to warrant the preparation of a Federalism 
Assessment.

CIVIL JUSTICE REFORM: This final rule does not have any retroactive 
effect. Under 49 U.S.C. 30103, whenever a Federal motor vehicle safety 
standard is in effect, a State may not adopt or maintain a safety 
standard applicable to the same aspect of performance which is not 
identical to the Federal standard, except to the extent that the State 
requirement imposes a higher level of performance and applies only to 
vehicles procured for the State's use. 49 U.S.C. 30161 sets forth a 
procedure for judicial review of final rules establishing, amending or 
revoking Federal motor vehicle safety standards. That section does not 
require submission of a petition for reconsideration or other 
administrative proceedings before parties may file suit in court.

List of Subjects in 49 CFR Part 571

    Imports, Motor vehicle safety, Motor vehicles.

    In consideration of the foregoing, 49 CFR Part 571 is amended as 
follows:

PART 571--FEDERAL MOTOR VEHICLE SAFETY STANDARDS

    1. The authority citation for Part 571 of Title 49 continues to 
read as follows:

    Authority: 49 U.S.C. 322, 30111, 30115, 30117, and 30166; 
delegation of authority at 49 CFR 1.50.


Sec. 571.207  [Amended]

    2. Section 571.207 is amended by revising the heading of S3 and 
adding a new definition of ``Seat adjuster'' to S3 in alphabetical 
order; and by revising S4.2.1, and S5.1.1 to read as follows:


Sec. 571.207  Standard No. 207, Seating Systems.

* * * * *
    S3  Definitions.
* * * * *
    Seat adjuster means the part of the seat that provides forward and 
rearward positioning of the seat bench and back, and/or rotation around 
a vertical axis, including any fixed portion, such as a seat track. In 
the case of a seat equipped with seat adjusters at different levels, 
the term means the uppermost seat adjuster.
* * * * *
    4.2.1  Seat adjustment. Except for vertical movement of nonlocking 
suspension type occupant seats in trucks or buses, each seat shall 
remain in its adjusted position when tested in accordance with the test 
procedures specified in S5.
* * * * *
    S5.1.1  For a seat whose seat back and seat bench are attached to 
the vehicle by the same attachments.
    (a) For a seat whose seat back and seat bench are attached to the 
vehicle by the same attachments and whose height is adjustable, the 
loads are applied when the seat is in its highest adjustment position 
in accordance with the procedure or procedures specified in 
S5.1.1(a)(1), S5.1.1(a)(2), or S5.1.1(a)(3), as appropriate.
    (1) For a seat whose center of gravity is in a horizontal plane 
that is above the seat adjuster or that passes through any part of the 
adjuster, use, at the manufacturer's option, either S5.1.1(b) or, if 
physically possible, S5.1.1(c).
    (2) For a seat specified in S5.1.1(a)(1) for which it is not 
physically possible to follow the procedure in S5.1.1(c), use 
S5.1.1(b).
    (3) For a seat whose center of gravity is in a horizontal plane 
that is below the seat adjuster, use S5.1.1(c).
    (4) For all other seats whose seat back and seat bench are attached 
to the vehicle by the same attachments, use S5.1.1(b).
    (b) Secure a strut on each side of the seat from a point on the 
outside of the seat frame in the horizontal plane of the seat's center 
of gravity to a point on the frame as far forward as possible of the 
seat anchorages. Between the upper ends of the struts attach a rigid 
cross-member, in front of the seat back frame for rearward loading and 
behind the seat back frame for forward loading. Apply the force 
specified by S4.2(a) or S4.2(b) horizontally through the rigid cross-
member as shown in Figure 1.
    (c) Find ``cg1,'' the center of gravity of the portion of the 
seat that is above the lowest surface of the seat adjuster. On each 
side of the seat, secure a strut from a point on the outside of the 
seat frame in the horizontal plane of cg1 to a point on the frame 
as far forward as possible of the seat adjusted position. Between the 
upper ends of the struts attach a rigid cross-member, in front of the 
seat back frame for rearward loading and behind the seat back frame for 
forward loading. Find ``cg2,'' the center of gravity of the 
portion of the seat that is below the seat adjuster. Apply a force 
horizontally through cg1 equal to 20 times the weight of the 
portion of the seat represented by cg1, and simultaneously apply a 
force horizontally through cg2 equal to 20 times the weight of the 
portion of the seat represented by cg2.
* * * * *
    Issued on July 15, 1994.
Christopher A. Hart,
Deputy Administrator.
[FR Doc. 94-17736 Filed 7-20-94; 8:45 am]
BILLING CODE: 4910-59-P

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