Interpretation ID: 77-3.41

TYPE: INTERPRETATION-NHTSA

DATE: 08/03/77

FROM: AUTHOR UNAVAILABLE; J. J. Levin, Jr.; NHTSA

TO: Coach & Equipment Sales Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your June 8, 1977, letter asking where a school bus sidewall ends and the bus roof begins for purposes of complying with the head protection zone requirements of Standard No. 222, School Bus Passenger Seating and Crash Protection.

You enclosed a sketch detailing the bus sidewall and roof structure. On that sketch, you have a section of the bus labeled "A" where the sidewall and roof structure join. You have called this a quarter panel section. However, from your sketch, it appears that this panel is divided into two segments, with one extending upward from the window a short distance and connecting with a second more rounded section that continues over the top of the bus. The National Highway Traffic Safety Administration (NHTSA) has determined that your interpretation that the section labeled "A" need not comply with the requirements of the standard is incorrect. The agency concludes that the portion of the "quarter panel" that is a continuation of the bus sidewall is exempted from the requirements. However, the rounded portion of the panel that is merely a continuation of the roof must comply with the standard.

In your other sketch you present a roof drawing of a larger school bus. The agency has determined that the section you have labeled "roof section" is the only section of the drawing subject to the head protection zone requirements of the standard.

SINCERELY,

Coach & Equipment Sales Corporation

June 9, 1977 Dictated June 8, 1977

Roger Tilton Counsel National Highway Traffic Safety Administration

Relating to our phone conversation to-day pertaining to the "head impact zone confines" I pose for you the following question:

Q. Using the simple line sketches enclosed, we request an interpretation of that area "not occupied by bus sidewall"?

It is our interpretation that the area marked "A" is considered to be a part of the sidewall section and would thus be excluded from the impact zone confines.

In that production dates for the post-April standards are rapidly approaching, we respectfully request a prompt response with your interpretation.

RICHARD L. KREUTZIGER Executive Vice-President

BIG BUS - CONVENTIONAL FULL SIZE

SMALL BUS - VAN CONVERSION TYPE

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