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Interpretation ID: nht76-2.18

DATE: 11/15/76

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Gillig Bros.

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of September 13, 1976, in which you ask whether Standard No. 222, School Bus Passenger Seating and Crash Protection, requires that the 20-inch maximum separation between the seating reference point and the rear surface of the restraining barrier be measured at the point of greatest distance between the two.

The restraining barrier you describe has padded tubing around its circumference which would be closer to the seating reference point than the center section of the barrier. The National Highway Traffic Safety Administration (NHTSA) interprets the requirements of paragraph S5.2.1 of Standard No. 222 to mean that the 20-inch distance must be measured from the seating reference point to the surface of the seat back or restraining barrier, exclusive of portions which protrude from the basic contour of the surface. The side tube portion would constitute such a protrusion.

SINCERELY,

September 13, 1976

Thomas W. Herlihy Office of Chief Counsel National Highway Traffic Safety Administration

We have a question relative to School Bus Safety Standard Number 222. The standard states "that there shall not be more than 20" from the seating reference point to the rear surface of the restraining barrier". This distance being measured along a horizontal longitudinal line through the S.R.P in the forward direction.

Our question is this: What is considered the rear surface. Is it part furthest to the rear, which in our case would be the padding on the side tube portion of our seat frame? Or is it considered to be the rear padding on the sheet metal center section of the seat?

Attached is a sketch which we hope will clarify our question.

As our new seat spacing design requirements hinge on your answer, we would appreciate your written answer as early as possible.

Lewis C. Coffey Chief Engineer

cc: TIMOTHY HOYT -- OFC. OF CRASHWORTHINESS

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