NHTSA Complaint #10240748 — 2008 TOYOTA RAV4

THIS IS MY EFFORT TO SUBMIT A COMMENT ON YOUR REGULATIONS, NOT A COMPLAINT OF AN INCIDENT. I WAS DIRECTED TO THIS FORM BY LOU MOLINA AT NHTSA. I AM A DRIVER WHO FOR HEALTH REASONS WISHES TO SIT ERECT. I AM NOT FAT, AND OF NORMAL HEIGHT (5'6"). THIS LAST WEEKEND I PURCHASED A RAV4. THE HEADRESTS INTRUDE INTOLERABLY INTO MY HEAD SPACE. IN ORDER TO SIT AT MY PREFERRED ANGLE AND KEEP MY BACK TO THE SEATBACK, MY HEAD IS TILTED DOWN SO THAT I MUST RAISE MY EYES TO LOOK OVER MY EYEGLASSES, OR MY STRAIGHT VISION IS DIRECTED TO THE CENTER OF THE STEERING WHEEL. I TRUST THAT THESE HEADRESTS MEET YOUR STANDARDS. IT IS MY BELIEF THAT YOU HAVE ENGINEERED THIS STANDARD FOR AN OBESE, FAT-SHOULDERED PERSON WITH TIGHT HAMSTRINGS, SOMEONE WHO PREFERS TO DRIVE RECLINED TO ACCOMMODATE HIS BELLY AND IS HELD AWAY FROM THE SEATBACK BY HIS OWN PADDING. MY PRESENT APPROACH TO BEING ABLE TO DRIVE THIS CAR IS TO TURN THE HEADREST BACKWARDS, AND I AM FULLY AWARE THAT THIS DEPRIVES ME OF THE NECK SAFETY I WOULD HAVE HAD FROM AN OLDER DESIGN OF HEADREST. I WOULD SUGGEST THAT THE COMMENTS IN SECTION VII OF RIN 2127-AH09, "SPECIFICALLY, THEY MAINTAINED THAT SMALLER FEMALE OCCUPANTS TEND TO UTILIZE STEEPER SEAT BACK ANGLES. ACCORDING TO THESE COMMENTERS, A BACKSEAT OF 50 MM MAY CAUSE SIGNIFICANT INTRUSIONS INTO THE SPACE WHERE THESE OCCUPANTS TYPICALLY PLACE THEIR HEADS, FORCING THEIR HEADS INTO AN UNNATURAL FORWARD-TILTING POSITION" IS DESCRIPTIVE OF MY SITUATION. IT IS IMPORTANT FOR THE NHTSA TO CONSIDER MINORITY AS WELL AS MAJORITY NEEDS IN DRAFTING SUCH REGULATIONS. AND IT IS IMPORTANT TO PROVIDE ALTERNATIVE SOLUTIONS TO DRIVERS WHOSE COMFORT AND SAFETY HAS BEEN DIMINISHED BY YOUR DECISIONS. THANK YOU, MELISSA READING *TR