Interpretation ID: 86-3.15

TYPE: INTERPRETATION-NHTSA

DATE: 05/07/86

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Karen Finkel -- Executive Director, National School Transportation Association

TITLE: FMVSS INTERPRETATION

TEXT:

Ms. Karen Finkel

Executive Director National School Transportation Association P.O. Box 26 Springfield Virginia 22152

This response to your March 3, 1986 letter to our office concerning requirements applicable to front seat restraining barriers on school buses. You asked whether the barriers meet the same Federal motor vehicle safety standards as the school bus seats. Specifically you are interested in barrier-seat separation and barrier performance requirements.

Federal Motor Vehicle Safety Standard No. 222, School Bus Passenger Seating and Crash Protection, establishes requirements for school bus seats and restraining barriers. Included in Standard No. 222 are paragraphs S5.2 through S5.2.3 which specifically apply to restraining barriers on school buses with gross vehicle weight ratings over 10,000 pounds. Since restraining barriers function to compartmentalize passengers in the same manner as school bus seats, the requirements of Standard No. 222 for barrier-seat separation distances and barrier strength are similar to the spacing and strength requirements for school bus seats. For example, S5.2.1 specifies that the distance between a restraining barrier's rear surface and the seating reference point of the first seat to the rear of the barrier must not be more than 24 inches. Also, under S5.2.3, barriers are tested for compliance with the forward performance requirements in the same manner as school bus seats. Both must withstand similar forces while maintaining component integrity. Force/deflection curves for seat backs and restraining barriers must fall within the zone specified in Figure 1 of Standard No. 222, and seat back and restraining barrier deflection must not exceed 14 inches. Further, restraining barriers and seat backs must meet the same impact zone requirements (S5.3) of the standard. Additional requirements for restraining barriers are specified in Standard No. 222. A copy of the standard is enclosed for your convenience.

You asked whether the front seat barrier is secured to the floor of the school bus in a different manner than the seats. Standard No. 222 does not specify how school bus restraining barriers or seats are to be secured to the floor of the bus. Manufacturers are free to select the manner of securing barriers and seats to the bus floor as long as those structures meet all applicable requirements of our safety standards.

I hope this information is helpful. Please contact our office if we can be of further assistance.

Sincerely,

Erika Z. Jones Chief Counsel

Enclosure

March 3, 1986

Mr. Jeffrey Miller, Chief Counsel National Highway Traffic Safety Administration 400 Seventh Street, S.W. Washington, DC 20590

Dear Mr. Miller:

A member of the National School Transportation Association has requested a legal opinion as to whether the front seat barriers on school buses have to meet the same federal motor vehicle safety standards as the seats.

He's specifically interested in distance, flexibility-rigidness, the angle of the barrier and whether the barrier is secured to the floor in a different manner than the seats.

Thank you for your assistance. Please let me know if you need any further information.

Sincerely,

Karen Finkel Executive Director

KF/sb

cc: Robert Christian