Interpretation ID: 77-1.28

TYPE: INTERPRETATION-NHTSA

DATE: 02/22/77

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Blue Bird Body Company

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your January 19, 1977, question whether the requirement of S5.2 of Standard No. 222, School Bus Passenger Seating and Crash Protection, for a restraining barrier of specified size in front of certain designated seating positions necessitates the provision of an additional barrier surface in front of those portions of a bench seat that do not form part of the designated seating positions. You describe a front-row two-passenger bench seat in a bus (with a seat back that extends beyond the bench to provide adequate restraint for a three-passenger seat aft of it) and ask about the restraining barrier that is required in front of the two-passenger front-row seat.

Paragraph S5.2.2 requires that the perimeter of the restraining barrier coincide with or lie outside of the perimeter of the seat back of the seat for which it is required. This means that the restraining barrier must coincide with or lie outside of the perimeter of the seat back of the designated seating position or positions for which it is required. Therefore, a seat with only two designated seating positions must only be equipped with a restraining barrier in front of those two seating positions.

SINCERELY,

BLUE BIRD BODY COMPANY

January 19, 1977

Frank Berndt Chief Counsel National Highway Traffic Safety Administration

The purpose of this leter is to get an interpretation regarding paragraph S5.2.2, Barrier Position and Rear Surface Area, of FMVSS 222, School Bus Passenger Seating and Crash Protection. The subject paragraph reads "The position and rear surface area of the restraining barrier shall be such that, in a front projected view of the bus, each point of the barrier's perimeter coincides with or lies outside of the perimeter of the seat back of the seat for which it is required."

In the development of this standard it has been our understanding that NHTSA was contemplating a possible passenger loss on the right front seat of the school bus. This would necessitate a special seat at the right front position which would have seating provision for two passengers and a seat back wide enough to provide barrier protection for the three passengers in the second front seat on the right side. With this configuration the barrier in front of the right front seat would be a two passenger barrier.

We have designed such a seating and barrier configuration as described above. * We would like confirmation of our interpretation that paragraph S5.2.2 allows this configuration.

* See enclosed photos showing mockup of this seat and barrier arrangement.

Thank you for your early attention and reply to this matter.

W. G. Milby Manager, Engineering Services

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