Interpretation ID: nht90-1.77

TYPE: INTERPRETATION-NHTSA

DATE: 03/20/90

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

TO: THOMAS D. TURNER -- MANAGER, ENGINEERING SERVICES, BLUE BIRD BODY COMPANY

TITLE: NONE

ATTACHMT: LETTER DATED 12-1-89 TO STEPHEN P. WOOD, NHTSA, FROM THOMAS D. TURNER, BLUE BIRD BODY CO., ATTACHED; [OCC-4230]

TEXT: This responds to your letter seeking an interpretation of the meaning of the term "front outboard designated seating position," for the purposes of Standards No. 202, Head Restraints (49 CFR @ 571.202) and No. 208, Occupant Crash Protection (49 CFR @ 571 .208). Specifically, you referred to a typical seating arrangement on a small bus your company manufacturers. In this seating arrangement, the driver's seating position is located immediately to the rear of the left side of dashboard. There are no oth er seating positions in the same row as the driver's seat. Instead, a side entrance door and stepwell are to the right of the driver's seat with an unobstructed passage between the driver's seat and the entrance door. To the rear of the driver's seat, there are four rows of passenger seats on each side of the bus, separated by a center aisle that runs the length of the bus. You offered you opinion that the forwardmost passenger seating position on the right side of the bus, which is to the rear of th e driver's seating position and the entrance door and stepwell, is not a front outboard seating position for the purposes of Standard No. 202 and 208. Your understanding is correct.

While NHTSA has never specifically defined "front" seating positions, the agency has used that term to refer to the driver's seating position and all other seating positions in the same transverse or lateral row as the driver's seating position. In the small bus described in your letter, the forwardmost passenger seat on the right side of the bus is not in the same transverse row as the driver's seat; it is to the rear of that row. Therefore, the forwardmost passenger seat on the right side of your bu s would not be a "front" seat for the purposes of Standards No. 202 or 208.