Interpretation ID: nht89-3.49

TYPE: INTERPRETATION-NHTSA

DATE: DECEMBER 1, 1989

FROM: THOMAS D. TURNER -- MGR., ENGINEERING SERVICES, BLUE BIRD BODY CO.

TO: STEPHEN P. WOOD -- ACTING CHIEF COUNSEL, NHTSA

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 3-20-90 TO THOMAS D. TURNER, BLUE BIRD BODY CO., FROM STEPHEN P. WOOD, NHTSA; [REDBOOK A35; STDS. 202 AND 208]

TEXT: Attached is an illustration of a typical seating arrangement for a small bus that we manufacture. The vehicle has a 10,000 pound GVWR. It is our understanding that the driver's seat is a outboard front designated seating position and that a passenger s eat if located in a similar position on the right side of the vehicle would be an outboard front designated seating position. However, as shown on the attached illustration, our vehicle has an entrance door and stepwell in the area on the right side oppo site the driver's seat. The forwardmost outboard passenger seating position on the right side is approximately in line (3 inches forward on the attached example) with the forwardmost outboard passenger seating position on the left side.

It is our understanding that these forwardmost attached passenger seating positions are not outboard front designated seating position for the purpose of the recently published final rule on Standard 202, 49CFR, Part 571, Docket Number 88-24; Notice 02, Federal Register Volume 54, Number 184, Monday, September 25, 1989 or for the occupant protection requirements of 49 CFR Part 571.208 Occupant Crash Protection.

We request your confirmation that our understanding is correct and that the forwardmoset outboard passenger seating positions of a bus, as shown on the illustration, are not outboard front designated seating positions.

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