Interpretation ID: aiam2435
Chief Engineer
Gillig Bros.
Box 3008
25800 Clawiter Road
Hayward
CA 94540;
Dear Mr. Coffey: This is in response to your letter of September 13, 1976, in which yo ask whether Standard No. 222, *School Bus Passenger Seating and Crash Protection*, requires that the 20-inch maximum separation between the seating reference point and the rear surface of the restraining barrier be measured at the point of greatest distance between the two.; The restraining barrier you describe has padded tubing around it circumference which would be closer to the seating reference point than the center section of the barrier. The National Highway Traffic Safety Administration (NHTSA) interprets the requirements of paragraph S5.2.1 of Standard No. 222 to mean that the 20-inch distance must be measured 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. The side tube portion would constitute such a protrusion.; Sincerely, Frank A. Berndt, Acting Chief Counsel