Interpretation ID: aiam2858
Assistant Superintendent for Business
West Seneca Central School District
45 Allendale
West Seneca
NY 14224;
Dear Mr. Yarbrough: This responds to your May 4, 1978, letter asking whether you can modif several buses that you have purchased by adding stanchion bars near the front door to facilitate the loading of smaller school children.; The National Highway Traffic Safety Administration does not prohibi the use of stanchion bars in school buses. Some manufacturers, however, have discontinued putting them in buses because it is difficult to pad them sufficiently such that they comply with the head impact zone requirements when the bars fall within the head impact zone.; The National Traffic and Motor Vehicle Safety Act of 1966 (the Act prohibits modification of vehicles by repair businesses, dealers, or manufacturers that would render inoperative compliance with safety standards (section 108(a)(2)(A)). Therefore, if a dealer, repair business, or manufacturer were to install stanchion bars in your school buses, it would be required to ensure that the installation does not render inoperative compliance with the head impact zone requirements. The Act does not prohibit, however, modifications by individuals of their vehicles even when such modification would not comply with Federal safety standards. Accordingly, a school district could itself install stanchion bars that do not comply with the head impact zone requirements.; Sincerely, Joseph J. Levin, Jr., Chief Counsel