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Interpretation ID: 22302.drn



    Monsieur Jean-Yves Le Bouthillier
    Standards Manager
    Les Entreprises Michel Corbeil Inc.
    304 12th Avenue
    Laurentides, Quebec JOR 1C0
    CANADA


    Dear Monsieur Le Bouthillier:

    This responds to your request for an interpretation addressed to Mr. Charles Hott, of the National Highway Traffic Safety Administration (NHTSA), regarding S5.3.1, Head protection zone, of Standard No. 222, School bus passenger seating and crash protection. Our answer is provided below.

    You provided three photographs of a school bus interior showing views between the driver's seat and the first row of passenger seats behind the driver's seat. One photograph shows the view from behind the first row of passenger seats toward the front of the bus. In this photograph is depicted a small partition that is attached to the left side of the school bus between the driver's seat and the first row of passenger seats. The partition appears to extend only partially over the driver's seat. No measurements are provided for this partition. Two photographs show a side view of the driver's seat, to the school bus interior roof. There appears to be a storage area covered by a door on the left wall of the bus above the driver's seat.

    On one photograph are placed two white squares (obscuring the driver's storage area) that apparently show where in the bus it is 58 1/4 inches (1479.5 mm) to the floor and 40 inches (1016 mm) "over the seating reference point" and where it is 30 inches (762 mm) "in front of the seating reference point." We will assume that these measurements are in relation to the seating reference point of the first row of passenger seats. The other photograph shows what the interior actually looks like (i.e., does not include the obscuring white squares). You wish to know whether the closed driver's storage area and the side partition must meet S5.3.1 of Standard

    No. 222. Based on the available information, the answer is yes.

    S5.3.1 of Standard No. 222 states, in relevant part: "Any contactable surface of the vehicle within any zone specified in S5.3.1.1 shall meet the requirements of S5.3.1.3. . . ." (1)

    S5.3.1.1 states that the head protection zones in each vehicle are "the spaces in front of each school bus passenger seat which are not occupied by bus sidewall, window, or door structure and which, in relation to that seat and its seating reference point, are enclosed by the following planes;"

      (a) Horizontal planes 305 mm and 1016 mm above the seating reference point:

      (b) A vertical longitudinal plane tangent to the inboard (aisle side) edge of the seat;

      (c) A vertical longitudinal plane 83 mm inboard of the outboard edge of the seat;

      (d) Vertical transverse planes through and 762 mm forward of the reference point.

    The issue you raise is whether the storage area and side partition are considered "bus sidewall" and thus excluded under S5.3.1.1. The storage area does not qualify for the exclusion. The closed storage area over the driver's seat is an overhead projection from the bus interior. NHTSA's longstanding position has been that "[t]he roof structure and overhead projections from the interior are included in [the head protection] area of the zone." (Final rule; response to petitions for reconsideration; 41 FR 28506, 28507; July 12, 1976; emphasis added.) Accordingly, we consider the storage area as not per se excluded. If the driver's storage area is located within horizontal planes 305 mm and 1016 mm above the seating reference point of the first row of passenger seats, the storage door must meet S5.3.1.2 and S5.3.1.3 of Standard No. 222.

    In addition, we do not consider the partition between the driver's seat and first row of passenger seats to be "bus sidewall." In a letter of April 28, 1978 to Wayne Corporation (copy enclosed), NHTSA interpreted "sidewall" to include "those surfaces that run parallel to the outboard edge of the forward facing seat." Based on your photographs, the partition appears to be perpendicular to the outboard edge of the forward facing seat. The partition also appears to be completely in the head protection zone, in which case, all surface areas of the partition (including the side of the partition facing the driver's seat) must meet S5.3.1.2 and S5.3.1.3.

    I hope this information is helpful. If you have any further questions, please feel free to contact Dorothy Nakama of my staff at this address or at (202) 366-2992.

    Sincerely,

    John Womack
    Acting Chief Counsel

    ref:222
    d.8/2/01



    1. 1 "Contactable surface" is defined in S4 of Standard No. 222 as "any surface within the zone specified in S5.3.1.1 that is contactable from any direction by the test device described in S6.6, except any surface on the front of a seat back or restraining barrier 76 mm or more below the top of the seat back or restraining barrier."