Interpretation ID: aiam2565
Executive Vice President
Coach & Equipment
P. O. Box 36
Penn Yan
NY 14527;
Dear Mr. Kreutziger: This responds to your March 15, 1977, letter asking whether the hea and knee form impact requirements of Standard No. 222, *School Bus Passenger Seating and Crash Protection*, apply to the stanchion post and cross bars installed in your buses.; School buses with gross vehicle weight ratings of 10,000 pounds or les are not required to have restraining barriers as mandated in S5.2 of the standard for larger buses. Therefore, there is no requirement that you install stanchions, cross bars, or panels in the buses you manufacture. Should you choose to install these devices, they would not be required to be as wide as the seat. Similarly, there would be no requirement pertaining to forward or rearward movement of these devices.; The leg protection zone as defined in S5.3.2 of the standard i measured with reference to seat backs and restraining barriers. Since the devices you mention are not considered as either seat backs or restraining barriers, the leg protection zone requirements do not apply.; The head protection zone requirements, on the other hand, apply to an contactable surface located within the zone defined in S5.3.1 of the standard. Since part of the stanchion to which you refer creates a contactable surface within the head protection zone, it must meet the requirements of the standard specified in S5.3.1.; Sincerely, Frank Berndt, Acting Chief Counsel