Interpretation ID: aiam2526
Director
Vehicle Safety Activities
Sheller- Globe Corporation
355 St. Johns Road
Lima
OH 45804;
Dear Mr. Premo: This responds to your February 8, 1977, question whether the use of front-row two-passenger bench seat with a three-passenger seat back requires a forward restraining barrier for two or three designated seating positions according to the requirements of Standard No. 222, *School Bus Passenger Seating and Crash Protection*.; The NHTSA answered this question on February 22, 1977, in response to request for an interpretation from Blue Bird Body Company. I am enclosing a copy of that interpretation for your information. You will note that Blue Bird accomplished the modification of the front-row seat by the installation of a two-passenger bench seat. As the interpretation indicates, the NHTSA requires a restraining barrier only in front of designated seating positions.; You also ask what procedure is required to obtain approval from th NHTSA for a particular Front-row seat design. Although the agency does not give formal 'approval' of designs, it is willing to give an opinion as to whether your design appears to satisfy the requirements of the standard. We require that you submit full detail (including pictures if possible) of the proposed design. In particular, we would like to know how you intend to render the excess 13 inches of frame permanently inoperative as a seating position. We would also be interested to know why you cannot install a two-passenger bench seat to obviate the problem of excess seat frame.; Sincerely, Frank A. Berndt, Acting Chief Counsel