Interpretation ID: aiam3944
Laboratory Technician
Failure Analysis Associates
10899 Kinghurst
Suite 245
Houston
TX 77099;
Dear Mr. Hawkins: This responds to your letter asking about Federal Motor Vehicle Safet Standard No. 207, *Seating Systems*. You asked whether buses are excluded from the requirements of section S4.2, section S4.3, and/or the static testing procedures of section S5. You also asked whether there are any other standards which provide criteria for the testing of seating systems on buses. The answers to your questions are provided below.; Section S2 of Standard No. 207 provides that the standard applies t buses (among other vehicle types). Section S4.2, *General performance requirements*, provides that '(w)hen tested in accordance with S5., each occupant seat other than a side- facing seat or a passenger seat on a bus, shall withstand' specified forces. Passenger seats on a bus are thus excluded from the requirements of section S4.2. However, the driver's seat on a bus is not excluded from the requirements of that section. The testing procedures of section S5 are only relevant to seats which are subject to the general performance requirements of section S4.2.; Similarly, section S4.3, *Restraining device for hinged or foldin seats or seat backs*, provides that '(e)xcept for a passenger seat in a bus or a seat having a back that is adjustable only for the comfort of its occupants, a hinged or folding occupant seat or occupant seat back shall' meet specified requirements. Passenger seats on a bus are thus excluded from the requirements of section S4.3. Assuming that a hinged or folding occupant seat or occupant seat back were provided for the driver, it would not be excluded from the requirements of that section unless it had a back that was adjustable only for the comfort of its occupant.; With respect to your last question, Federal Motor Vehicle Safet Standard No. 222, *School Bus Passenger Seating and Crash Protection*, specifies criteria for the testing of school bus passenger seats. That standard is not applicable to buses other than school buses. The agency does not have any other standards which provide criteria for testing seating systems of buses.; Sincerely, Jeffrey R. Miller, Chief Counsel