Interpretation ID: aiam2986
Manager
Engineering Services
Blue Bird Body Company
P.O. Box 937
Fort Valley
GA 31030;
Dear Mr. Milby: This responds to your March 1, 1979, letter asking the National Highwa Traffic Safety Administration to withdraw an earlier interpretation of Standard No. 222, *School Bus Passenger Seating and Crash Protection*, which stated that any contactable objects falling within the head protection zone must comply with the head impact and force distribution requirements. The head protection zone might include some areas in the driver's seating location, and therefore, any contactable object in the driver's seating location that falls within the zone must comply with the requirements. The agency declines to alter its interpretation.; The standard is clear in its specification of zones for head for impact and force distribution testing. These zones help to ensure that any contactable objects falling within them will be sufficiently padded to protect a child from serious injury in an accident. The head protection zone for any passenger seat extends into the seat area of the passenger seat immediately in front of it. Similarly, the zone for the front passenger seat might extend into the driver's seating location. You argue that the restraining barrier between the front seat and the driver's seat removes the need for head protection zone requirements in the driver's seating area.; The fact that a restraining barrier separates the driver's seatin location from the passenger seat bears no relevance to the need for head impact protection in the head protection zone for the front passenger seat. The head protection zone extends above and beyond the restraining barrier recognizing the possibility that the heads and upper bodies of larger children are likely to be impelled somewhat beyond the barrier in an accident. The barrier should help to prevent a child from being thrown entirely out of its seating position, but a barrier cannot prevent a child's head from being propelled beyond the barrier in some instances. Since the head protection zone requirements are designed to provide protection in these situations and that protection is needed for all passenger seats including the front seat, the agency will not alter its interpretation of the requirements as they apply to the head protection zone for the front passenger seat.; Sincerely, Frank Berndt, Chief Counsel