Interpretation ID: aiam4242
Safety Specialist
Kansas Department of Transportation
Bureau of Personnel Services
7th Floor
State Office Building
Topeka
KS 66612;
Dear Mr. Edwards: I am writing in response to your recent inquiry concerning interio over-head luggage racks on school buses. Your first question seeks this Agency's opinion on whether interior luggage racks on school buses should be considered 'projections likely to cause injury' under the National Minimum Schoolbus Standards. These standards are recommendations by the National Conference on School Transportation (NCST), and are not developed by NHTSA. Requests for interpretation of these Standards should be mailed to the Interpretation Committee, addressed to:; >>>Mr. Norman Loper, Coordinator of Pupil Transportation, Alabam Department of Education, 304 Dexter Avenue, Montgomery, AL 36130<<<; Requests for modification to these Standards and development of ne Standards should be directed to the chairman of the Interim Committee, addressed to:; >>>Mr. Bill G. Loshbough, Asst. State Supt. for Transportation, Dept of Education, Education Bldg., Santa Fe, NM 87501-2786<<<; In response to your second question, there are no federal standards o regulations which specifically address the issue of over-head luggage racks on school buses. However, Federal Motor Vehicle Safety Standard No. 222, 49 Code of Federal Regulations (CFR) S571.222 addresses the issue of school bus passenger seating and crash protection. Specifically, S5.3.1 of that standard establishes the head protection zones. As defined in S5.3.1.1, that zone extends up to a horizontal plane 40 inches above the seating reference point. If the luggage rack were to be located within the head protection zone, the rack would have to meet the head form impact requirement in S5.3.1.2 and the head form force distribution requirement in S5.3.1.3.; Please feel free to contact this office if you have any othe questions.; Sincerely, Erika Z. Jones, Chief Counsel