Stressed Seats - What is required to prove compliance

[jacko]

For aftermarket stressed seats to be compliant they need to meet one (or more) of the following out of the LTSA

LTSA 32004
2.3(2) The approved vehicle standards for seats and seat anchorages are:

(a) UN/ECE Regulation No. 17, Uniform provisions concerning the approval of vehicles with regard to the seats, their anchorages and any head restraints (E/ECE324-E/ECE/TRANS/505/Rev.1/Add.16);

(b) Council Directive of 22 July 1974 on the approximation of the laws of the Member States relating to the interior fittings of motor vehicles (strength of seats and their anchorages) (74/408/EEC);

(c) Federal Motor Vehicle Safety Standard No. 207, Seating Systems – Passenger Cars, Multipurpose Passenger Vehicles, Trucks, and Buses;

(d) Technical Standard for Seats and Seat Anchorages (Japan);

(e) Australian Design Rule 3/02, Seats and Seat Anchorages


What is required to prove compliance with one of the above? Im trying to get Recaro seats and rails approved, but so far all I can find from Recaro is that all their seats and rails (when matched rail/seat/car using their app) meet compliance requirements. This is apparently too generic a statement. Struggling to find anything specific to my seats and rails, short of a TUV compliance for another car (E90 vs E87 BMW)

Any guidance on what the minimum proof is? The seats and rails I have are definitely compliant, has all the TUV ABE approvals stamped all over them, but I dont have (and apparently neither do Recaro) anything for my specific seat/rail combo... they just apparently rely on everything they do being compliant/exceeding the standards.

[Chris]

Jul 11, 2023 9:18:44 GMT 12 jacko said:

For aftermarket stressed seats to be compliant they need to meet one (or more) of the following out of the LTSA

LTSA 32004
2.3(2) The approved vehicle standards for seats and seat anchorages are:

(a) UN/ECE Regulation No. 17, Uniform provisions concerning the approval of vehicles with regard to the seats, their anchorages and any head restraints (E/ECE324-E/ECE/TRANS/505/Rev.1/Add.16);

(b) Council Directive of 22 July 1974 on the approximation of the laws of the Member States relating to the interior fittings of motor vehicles (strength of seats and their anchorages) (74/408/EEC);

(c) Federal Motor Vehicle Safety Standard No. 207, Seating Systems – Passenger Cars, Multipurpose Passenger Vehicles, Trucks, and Buses;

(d) Technical Standard for Seats and Seat Anchorages (Japan);

(e) Australian Design Rule 3/02, Seats and Seat Anchorages


What is required to prove compliance with one of the above? Im trying to get Recaro seats and rails approved, but so far all I can find from Recaro is that all their seats and rails (when matched rail/seat/car using their app) meet compliance requirements. This is apparently too generic a statement. Struggling to find anything specific to my seats and rails, short of a TUV compliance for another car (E90 vs E87 BMW)

Any guidance on what the minimum proof is? The seats and rails I have are definitely compliant, has all the TUV ABE approvals stamped all over them, but I dont have (and apparently neither do Recaro) anything for my specific seat/rail combo... they just apparently rely on everything they do being compliant/exceeding the standards.


View Attachment

Hi Jacko

The LTSA (Land Transport Safety Authority) has not been around for 20 years, however, I think you might have jumped the gun going to the Land Transport Rule.

Are you trying to certify seats and seat rails in a Low Volume Vehicle? What is the specific issue you are having?

Regards

Chris

[jacko]

Sorry, Land Transport Rule rather than LTSA. Rule 32004 - www.nzta.govt.nz/assets/resources/rules/docs/seats-and-seat-anchorages-2002.pdf

Car is going through LVVTA cert process, but has hit a snag in that need to prove compliance to that (2.3(2)) to comply with - www.lvvta.org.nz/documents/standards/LVVTA_STD_Seats_&_Seat_Anchorages.pdf

Section 1.3(3) b(ii) -
results directly equivalent to those required by one of the approved standards specified in 2.3 of the Land Transport Rule 32004: Seats and Seat Anchorages 2002, or Australian Code of Practice VSB5A Commercial Manufacture and Installation of Seats have been achieved;

Section 2.6(3) -
A forward-facing stressed after-market or custom one-off seat may be retro-fitted to a low volume vehicle, provided that either:
(a) the seat complies with one or more of the approved standards specified in 2.3 of the Land Transport Rule 32004: Seats and Seat Anchorages 2002;

So my stressed aftermarket seats need to comply with one of the standards listed in the LTR 32004 2.3(2)... which they do, but, the compliance is a generic statement rather than a specific one.  Im wondering what level of documentation I need to prove their compliance to any of the above standards.

[Chris]

Jul 11, 2023 17:12:49 GMT 12 jacko said:

Sorry, Land Transport Rule rather than LTSA. Rule 32004 - www.nzta.govt.nz/assets/resources/rules/docs/seats-and-seat-anchorages-2002.pdf

Car is going through LVVTA cert process, but has hit a snag in that need to prove compliance to that (2.3(2)) to comply with - www.lvvta.org.nz/documents/standards/LVVTA_STD_Seats_&_Seat_Anchorages.pdf

Section 1.3(3) b(ii) -
results directly equivalent to those required by one of the approved
standards specified in 2.3 of the Land Transport Rule 32004: Seats and
Seat Anchorages 2002, or Australian Code of Practice VSB5A
Commercial Manufacture and Installation of Seats have been
achieved;

So my stressed aftermarket seats need to comply with one of the standards listed in the LTR 32004 2.3(2)... which they do, but, the compliance is a generic statement rather than a specific one.  Im wondering what level of documentation I need to prove their compliance to any of the above standards.

Hi Jacko

We would expect something like a statement from the manufacturer of the seat that states the seat has been tested to and meets one of the approved standards as per the Seats and Seat Anchorages 2002 rule, if the test was vehicle specific, then the statement will need to specify the make and model of vehicle that the seat is being installed into.

However, my understanding is that 2.3 relates to original equipment more than aftermarket seats and I expect such a statement would be difficult to get from the manufacturer for an aftermarket stressed seat unless they actually make a seat specifically for a model of vehicle. We do not typically see aftermarket stressed seats being fitted outside of vans (as they usually have flat floors) and I would suggest that an easier option is to fit the seatbelt buckle to doubler plates in the floor and the seatbelt to the B or C-pillar. We have recipes for these in our seatbelt anchorages standard.

Hopefully that helps.

Chris

[jacko]

Thats where it gets weird with "proper" seat manufacturers, in that they do test to the various standards. The LVV doc points to 2.3 for aftermarket stressed seats standards.

There is an example of my particular seats, with different p/n rails to suit the slightly different car, being testing to German TUV standards (based on the EU standard, but certified to individual vehicle types) in a BMW E90 (3 series), but TUV never tested them in an E87 (1 series), so there is no specific test with the seats and rails bolted into my car. E87 Vs E90 is 90% the same car, with essentially only different body panels. There is also a statement in the Recaro docs that they test seats and rails to twice (40g) the G loading requirements of the various standards.

The only statement I can find from Recaro, am in an email conversation with them but not confident of getting further info, is what's attached above: All Recaro seats (other than the race ones) when using recaro rails comply with EU/Japan/US standard. Which is apparently too generic, hence what I am after is the minimum standard of a statement from Recaro.

I very hesitant to go the other route and modify the car with doubler plates etc, when the seats and rails are compliant, and car is relatively rare. Chopping/Welding it up seems pretty crude way of gaining compliance with it for LVV Cert.

Thanks for your help.

[jacko]

Hello, still havent got an answer on this?

What is acceptable to the LVVTA to prove the compliance of with one of the standards mentioned 2.3 of the LTSA Rule 32004?

The rails, and seats, have been designed by a reputable seat manufacturer (probably the most reputable) to mount into my specific car and meet the applicable standard, and this compliance is documented, however the statement Recaro provide is a generic one that all of their seats do. 

[Chris]

Hi Jacko


I answered your question above. Reposted here for your convenience.

Jul 11, 2023 17:38:12 GMT 12 Chris said:

Jul 11, 2023 17:12:49 GMT 12 jacko said:

Hi Jacko

We would expect something like a statement from the manufacturer of the seat that states the seat has been tested to and meets one of the approved standards as per the Seats and Seat Anchorages 2002 rule, if the test was vehicle specific, then the statement will need to specify the make and model of vehicle that the seat is being installed into.

However, my understanding is that 2.3 relates to original equipment more than aftermarket seats and I expect such a statement would be difficult to get from the manufacturer for an aftermarket stressed seat unless they actually make a seat specifically for a model of vehicle. We do not typically see aftermarket stressed seats being fitted outside of vans (as they usually have flat floors) and I would suggest that an easier option is to fit the seatbelt buckle to doubler plates in the floor and the seatbelt to the B or C-pillar. We have recipes for these in our seatbelt anchorages standard.

Hopefully that helps.

Chris

Regards

Chris