Interpretation ID: aiam2821
Manager
Engineering Services
Blue Bird Body Company
P.O. Box 937
Fort Valley
GA 31030;
Dear Mr. Milby: This responds to your April 24, 1978, letter asking two question concerning Standard No. 222, *School Bus Passenger Seating and Crash Protection*.; In your first question, you ask what the National Highway Traffi Safety Administration (NHTSA) means by the phrase 'seat components shall not separate at any attachment point.' This phrase is found in the forward and rearward loading performance tests. You suggest that the NHTSA interpret this to mean a complete separation of a seat component from another component. The NHTSA disagrees with this suggestion.; The standard as written clearly indicates that the agency has intende that seat components remain connected at all attachment points during testing. If the agency had intended a complete separation of seating components to be the test for separation, it would have used that language in the drafting of the regulation. Therefore, the agency declines to adopt the interpretation that you suggest and will require the seat to remain attached at all attachment points during testing.; Your second suggestion concerns a possible problem in the computatio of loads during rearward testing. You state that occasionally the loading bar will become buried in the upholstery material and, therefore, distort the actual seat loads. The NHTSA has not noted the phenomenon to which you refer. However, if it were to occur in compliance testing the agency would be certain to factor out any aberrations in the test results that occurred owing to this loading bar problem.; Sincerely, Joseph J. levin, Jr., Chief Counsel