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The National Highway Traffic Safety Administration (NHTSA) has recently opened a rulemaking docket seeking comments on the design of automobile seats and their performance in rear Impacts. There are two philosophies of seat design: one advocates rigid seats, the other advocates seats which yield in a controlled manner. A review of the legislative history of seat back design standards indicates that yielding seats have historically been considered a better approach for passenger cars. The design characteristics of current production automobile seats are evaluated and show no significant changes over the past three decades. Concerns about the performance of rigid seat backs in real world rear impacts are discussed, specifically increased injury exposure due to ramping, rebound and out-of-position occupants.