Interpretation ID: aiam2281
Staff Engineer
Blue Bird Body Company
P.O. Box 937
Fort Valley
GA 31030;
Dear Mr. Milby: This responds to Blue Bird Body Company's March 29 and 31, 1976, an April 14, 1976, requests for confirmation of several interpretations you have made regarding the new safety standards for school buses and the definition of school bus' as they become effective in October 1976.; Your interpretation is correct that bus passenger compartment' as use in S5.2.3.1 of Standard No. 217, *Bus Window Retention and Release*, means that portion of the bus that is rearward of the forwardmost point on the windshield.; You request confirmation that the requirement in S5.7(a) of Standar No. 220, *School Bus Rollover Protection*, to open emergency exits during the application of force to the bus roof are inappropriate and therefore not applicable in the case of roof exits. Your interpretation is correct, and the NHTSA intends to modify the language of Standard No. 220 appropriately.; You request confirmation that the knee impact requirement of S5.3.2. of Standard No. 222, *School Bus Passenger Seating and Crash Protection*, does not apply to the rear row of seating in a school bus because there is no passenger seating behind this row. Your interpretation is correct. I would like to point out that the seat back of the rear row of seating also is not subject to the requirements of S5.3.1.1 for the same reason. You are also correct that school bus passenger seat' as defined in S4 does not include a wheelchair that is placed in a school bus to transport non-ambulatory bus passengers. Our response on other issues concerning special arrangements for handicapped passengers will be forthcoming as a response to the outstanding Sheller- Globe petition for reconsideration of Standard No. 222.; In your March 31, 1976, letter you asked whether a bus that is sold fo purposes that include carrying kindergarten and nursery school children to and from school or related events would be considered a school bus under the redefinition of school bus' that becomes effective October 27, 1976 (40 FR 60033, December 31, 1975). The answer to your question is yes, because the statutory definition underlying the NHTSA definition of school bus specifically lists preprimary students as passengers of school buses. See 15 U.S.C. S1391(14).; In your April 14, 1976, letter you ask whether the requirement o S5.3.1.3 of Standard No. 222 for a minimum contact area' on a described spherical head form refers to the area of actual contact on the surface of the spherical head form, or the area of contact on the head form as seen in projected view. The contact area' refers to the area of actual contact on the surface of the head form.; Sincerely, Frank Berndt, Acting Chief Counsel