Interpretation ID: aiam2643
Executive Vice-President
Coach & Equipment Sales Corporation
P.O. Box 36
Penn Yan
NY 14527;
Dear Mr. Kreutziger: This responds to your June 8, 1977, letter asking where a school bu sidewall ends and the bus roof begins for purposes of complying with the head protection zone requirements of Standard No. 222, *School Bus Passenger Seating and Crash Protection*.; You enclosed a sketch detailing the bus sidewall and roof structure. O that sketch, you have a section of the bus labeled 'A' where the sidewall and roof structure join. You have called this a quarter panel section. However, from your sketch, it appears that this panel is divided into two segments, with one extending upward from the window a short distance and connecting with a second more rounded section that continues over the top of the bus. The National Higheay Traffic Safety Administration (NHTSA) has determined that your interpretation that the section labeled 'A' need not comply with the requirements of the standard is incorrect. The agency concludes that the portion of the 'quarter panel' that is a continuation of the bus sidewall is exempted from the requirements. However, the rounded portion of the panel that is merely a continuation of the roof must comply with the standard.; In your other sketch you present a roof drawing of a larger school bus The agency has determined that the section you have labeled 'roof section' is the only section of the drawing subject to the head protection zone requirements of the standard.; Sincerely, Joseph J. Levin, Jr., Chief Counsel