Federal Motor Vehicle Safety Standards Seating Systems; Pedestal Seats |
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Topics: National Highway Traffic Safety Administration, Federal Motor Vehicle Safety Standards
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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