Interpretation ID: aiam3528
Specifications Manager
Indiana Mills & Manufacturing
Inc.
120 West Main Street
Carmel
IN 46032;
Dear Mr. Lawler: This responds to your recent letter asking whether paragraph S4.2.2 o Safety Standard No. 208, *Occupant Crash Protection*, is applicable to school buses with a GVWR of 10,000 pounds or less.; The answer to your question is yes. Safety Standard No. 222 specifie in paragraph S5(b) that all seats, other than the driver's seat, in school buses with a GVWR of 10,000 or less shall meet the requirements of Safety Standard No. 208 as they apply to multipurpose passenger vehicles. The requirements for multipurpose passenger vehicles in Standard No. 208 are found in paragraph S4.2.2 for vehicles manufactured on or after January 1, 1976. There is no exception in S4.2.2 which allows school buses to comply with S4.2.1.2 of Standard No. 208.; School buses are not specifically mentioned in paragraph S4.2.2 o Standard 208, because that standard includes separate requirements for buses (including school buses) in paragraph S4.4. Under the general bus requirements of Standard 208, only the driver's position must be equipped with a seat belt. These requirements are supplemented by the more specific provision in Standard No. 222 which, as noted earlier, requires small school buses to meet the requirements of Standard 208 as they apply to multipurpose passenger vehicles.; I hope this has clarified your understanding of the requirements o these two standards. Please contact Hugh Oates of my staff if you have any additional questions (202-426-2992).; Sincerely, Frank Berndt, Chief Counsel