Interpretation ID: 77-2.26

TYPE: INTERPRETATION-NHTSA

DATE: 05/02/77

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Coach & Equipment

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your March 15, 1977, letter asking whether the head and knee form impact requirements of Standard No. 222, School Bus Passenger Seating and Crash Protection, apply to the stanchion post and cross bars installed in your buses.

School buses with gross vehicle weight ratings of 10,000 pounds or less are not required to have restraining barriers as mandated in S5.2 of the standard for larger buses. Therefore, there is no requirement that you install stanchions, cross bars, or panels in the buses you manufacture. Should you choose to install these devices, they would not be required to be as wide as the seat. Similarly, there would be no requirement pertaining to forward or rearward movement of these devices.

The leg protection zone as defined in S5.3.2 of the standard is measured with reference to seat backs and restraining barriers. Since the devices you mention are not considered as either seat backs or restraining barriers, the leg protection zone requirements do not apply.

The head protection zone requirements, on the other hand, apply to any contactable surface located within the zone defined in S5.3.1 of the standard. Since part of the stanchion to which you refer creates a contactable surface within the head protection zone, it must meet the requirements of the standard specified in S5.3.1.

SINCERELY,

Coach & Equipment Sales Corporation

March 15, 1977

Roger Tilton Counsel National Highway Traffic Safety Administration

Enclosed is a colored print which depicts the head and knee impact zone as we presently understand the standard.

The questions which we feel are pertinent to our problems are as follows:

1. Utilizing a 1" O.D. steel tube section located as shown will both the head and knee impact zone areas require padding to meet the individual pad requirements?

2. Must the stanchion and cross bar be as wide as the seat on each side?

3. For compliance with the standard would a steel (padded) panel be required on each, or either side?

4. Would the stanchion post and cross bar section require any restrictions relating to movement fore and aft?

Perhaps with the mails crossing paths we both will have a better understanding late this week.

I have also enclosed, for your information, our 1976 brochure showing our pre April 1, 1977 production unit.

If we have any further questions we will contact you directly and would much appreciate your doing likewise.

Richard L. Kreutziger Executive Vice President