letter to the CRB
in case anyone is interested, this is what I submitted (letter 2457, reviewed by GCR committee and sent to BoD)
Proposed rule, August 2010 Fastrack:
In 9.3.41, first paragraph, replace “Seat supports shall be of the type listed on FIA technical list No.12 (lateral, bottom,
etc).” with “Seat supports shall be of the type listed on FIA technical list No. 12 or No. 40 (lateral, lower, floor, back, etc) .In accordance with the FIA standards, the seat supports (brackets) must be those used when the seat was tested for homologation. Unless supporting evidence is provided by the manufacturer of a series produced car that shows FIA safety cage testing for homologation included an adjustable seat mount, seats and their supports must be attached to a fixed mounting structure.”
I recommend changing the language above to reflect that seats conforming to FIA standard 8855-1999, as listed in technical listing No. 12, are homologated with only the ”type” of bracket intended (8855-1999, 1.2) and NOT a specific seat mount part number. Technical list No. 40 specifies part numbers for the mount(s) used as they are homologated with the seat. Per 8862-2009, section 4.8 Seat-Brackets: “The seat brackets shall be considered part of the seat and shall share the seat homologation number.” This is a distinction that I think should be noted in the GCR as it has been misunderstood by many. It should be noted that the mounting of an 8855-1999 seat is subject to some level of official approval of fitness – I suggest this be by the scrutineer performing the annual inspection. It is odd to me that both the current and proposed rules are so devoid of specifics concerning the seat mounting. As a set of minimum criteria is needed in order to make a consistent determination in this regard, I propose a minimum of 3mm thick steel or 5mm thick aluminum should be used for mount brackets that are not identifiable as being from the manufacturer of the seat (be they generic, custom, or unmarked). These material dimensions are based on a sampling of the available offerings from several FIA-approved seat manufacturers. Seat mounts should be attached to the structure of the vehicle in such a way as to prevent movement in a collision; I recommend that it be in accordance with the driver’s restraint rules in 9.3.19.F. I also suggest the addition of ISO grade 8.8 as an alternate minimum fastener due to the common practice of using metric threads in FIA seat mounting bosses.
I believe that any rule requiring the addition of a back brace to a safely mounted seat is not well founded, even if well intended. FIA seats are typically NOT built to accommodate the installation of a back brace, and leaving the design of such a device to the competitor could result in required mounting that compromises the integrity of the seat back structure and could potentially cause serious, unintended harm to the driver. I have spoken to resellers and factory representatives from Cobra, Momo, Sparco, and OMP who all state that the addition of a seat-back brace to an FIA seat, particularly a composite shell seat, is dangerous and not recommended. Many of them offered stories of seats with back braces bolted to them that had cracked or been otherwise severely compromised in a wreck. Requiring replacement seat in order to properly accommodate a seat back brace could be crippling to a racer’s budget, particularly as many are still preparing to purchase required head and neck restraints, updated belts, etc…
Additionally, adjustable mounts for use in endurance cars can be a defacto requirement. Given the variety of cars that often cannot fit a back brace to allow both short and tall drivers (del sol, MR2, X1/9, etc…), and the potential for injury should the installed device compromise the seat back, there needs to be some language or provision for the use of adjustable mounts that conform to some acceptable standards that will allow the use of an 8855-1999 homologated seat without a back brace. These mounts need not (and in most cases, should not) be those supplied with the vehicle, but could be the type sold by the manufacturer of the seat or custom fabricated for the purpose and subject to some approval either at the scrutineering level or through a compliance review such as GCR 8.1.4. As it is very important to a large portion of the active community that there be a way to approve well designed mounting that permits quick repositioning of the seat, said rule must not rely solely on the seat or car manufacturer to offer an FIA approved adjustable mount, particularly as there is no applicable FIA standard for seat mounting brackets outside of 8862-2009 where they are co-homologated with the seat – meaning only certain exotic GT’s might meet the criteria as proposed.
As such, I recommend the following language in place of that proposed:
Seats homologated to FIA standard 8855-1999 are listed on FIA technical list No. 12 along with the type of support used in homologation, i.e. lateral or lower. In accordance with the FIA standards, the seat supports (brackets) must be the type used when the seat was tested for homologation. Where seat mounting brackets are not, or cannot be identified as being of the same manufacturer as the seat, a minimum material thickness of 3mm steel and 5mm aluminum alloy shall be used. Lower mount seats may be mounted directly to the floor of a production based vehicle, provided the attachment meets the minimum criteria outlined herein. Scrutineering shall be responsible for making a determination of the fitness of a seat mount and its installation.
Seats homologated to FIA 8862-2009 shall use the brackets homologated with the seat as listed in FIA technical list No. 40.
Seat brackets may be welded or bolted to the frame or roll structure of the car, bolted to the factory seat mounting bosses, or to steel floor boards of production based cars using 2” minimum diameter washers or equivalent. All bolts used should be SAE grade 5 or ISO 8.8 minimum, hardware without grade markings is unacceptable. Holes in the roll cage to facilitate bolting shall be bushed and welded completely.
Unless supporting evidence is provided by the manufacturer that shows FIA safety cage testing for homologation included an adjustable seat mount, seats and their supports must be attached to a fixed mounting structure. Exceptions may be approved on a case by case basis by a National or Senior Scrutineer or through the Compliance Review process (see 8.1.4). Mass produced items may be approved by the CRB and listed in the GCR.
The competitor is required to have a copy of the relevant FIA technical list and any additional homologation certificates or other certifying documentation on hand at all events.
