Interpretation ID: 77-1.45

TYPE: INTERPRETATION-NHTSA

DATE: 03/16/77

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Sheller Globe Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your February 8, 1977, question whether the use of a front-row two-passenger bench seat with a three-passenger seat back requires a forward restraining barrier for two or three designated seating positions according to the requirements of Standard No. 222, School Bus Passenger Seating and Crash Protection.

The NHTSA answered this question on February 22, 1977, in response to a request for an interpretation from Blue Bird Body Company. I am enclosing a copy of that interpretation for your information. You will note that Blue Bird accomplished the modification of the front-row seat by the installation of a two-passenger bench seat. As the interpretation indicates, the NHTSA requires a restraining barrier only in front of designated seating positions.

You also ask what procedure is required to obtain approval from the NHTSA for a particular front-row seat design. Although the agency does not give formal "approval" of designs, it is willing to give an opinion as to whether your design appears to satisfy the requirements of the standard. We require that you submit full detail (including pictures if possible) of any proposed design. In particular, we would like to know how you intend to render the excess 13 inches of frame permanently inoperative as a seating position. We would also be interested to know why you cannot install a two-passenger bench seat to obviate the problem of excess seat frame.

SINCERELY,

SHELLER-GLOBE CORPORATION Vehicle Planning and Development Center

February 8, 1977

Frank R. Berndt Office of Chief Counsel NHTSA

REF: FMVSS 222

Sheller-Globe Corporation is requesting an interpretation of S.5.2.2 barrier position and rear surface area of FMVSS 222 - School Bus Passenger Seating and Crash Protection.

Some states have for many years required a 24 inch clearance between the driver's stanchion and stepwell stanchion and are concerned about the 12 inch aisle between the barriers closing this area at the stepwell and entrance door.

Our question relates to the possibility of supplying front right-hand and/or left-hand seat with a 39 inch seat back and using a two passenger or 26 inch wide seat, cushion with a barrier width also of 26 inch width.

The 39 inch seat is used as an example with the understanding the same question also refers to other size seats such as 45, 36, 34, etc.

If this type seat and barrier will comply with your requirement and a method is devised to make the remaining 13 inches of the seat frame as to render it unusable as a seating area, what procedure is required to obtain approval from NHTSA that the particular design is determined to be a none seating position.

Your prompt attention is requested due to April 1, 1977, effective date and many questions from states reviewing their standards.

R. M. Premo - Director Vehicle Safety Activities