Interpretation ID: 77-4.14

TYPE: INTERPRETATION-NHTSA

DATE: 10/07/77

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

TO: Wisconsin School Bus Association

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your August 29, 1977, letter requesting an interpretation of Standard No. 222, School Bus Passenger Seating and Crash Protection, that would permit the measurement of seat spacing at any point along the width of the seat back.

The National Highway Traffic Safety Administration (NHTSA) has previously responded to a similar request for an interpretation of the measurement of seat spacing. I am enclosing a copy of that letter for your information. In that letter, the NHTSA stated that measurement of seat spacing must be made 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. This interpretation prohibits the measurement of seat spacing from the seating reference point to the side tubing which protrudes from the basic contour of the seat.

The NHTSA has received your second letter requesting rulemaking on the issue of seat spacing. That letter is being treated as a petition for rulemaking and will be processed according to agency rulemaking procedures.