Interpretation ID: aiam2593
Director of Engineering
Collins Industries
Inc.
P.O. Box 58
Hutchinson
KS 67501;
Dear Mr. Beach: This responds to your April 28, 1977, letter in which you ask severa questions concerning Standard No. 222, *School Bus Passenger Seating and Crash Protection*, and the definition of school bus.; You first ask whether the seat spacing requirements found in S5.2.1 o the standard are applicable to buses with gross vehicle weight ratings (GVWR) equal to or less than 10,000 pounds. Buses in this weight classification do not have to comply with the mandatory seat spacing requirements. Since these buses are equipped with seat belts, the mandatory seat spacing is not necessary to provide adequate occupant crash protection.; Your second question concerns those areas required to meet the hea protection zone requirements. You ask whether the window frame, window supporting structure, and window glass are included within the head protection zone requirements.; The NHTSA issued an amendment of the standard (Notice 6, 41 FR 28506 in an attempt to clarify those portions of the bus subject to the head protection zone requirements. In this notice (copy enclosed), we stated that the sidewall, window and door structures were never intended to be included within the zone and are not subject to the requirements for head protection. However, the roof structure, if it falls within the zone, is subject to the requirements. If you need further information to determine the portions of your bus that would be included within the head protection zone requirements, I suggest that you send the agency sketches of your bus interior depicting those areas of concern.; Concerning seat orientation, you question whether the requirements fo forward facing seats found in S5.1 of the standard applies to buses with GVWR's of 10,000 pounds or less. S5(b) of the standard lists the paragraphs of the standard applicable to buses in the above-mentioned weight classification. S5(b) does not refer to S5.1 which contains the requirement for forward facing seats. This omission was an oversight that occurred during the drafting of the regulation. The agency intended that seats in all school buses be forward facing, unless designed for handicapped or convalescent passengers as permitted in Notice 6. This intent is obvious since, as you note, we require these seats to comply with forward and rearward performance requirements. The NHTSA will soon issue an amendment of the standard to correct this omission.; Your final question concerns the definition of school bus whic excludes common carriers in urban transportation. Your interpretation of this exclusion is correct. These buses are permitted to transport children to and from school but need not comply with the school bus construction standards.; Sincerely, Joseph J. Levin, Jr., Chief Counsel