Interpretation ID: nht94-1.33

TYPE: Interpretation-NHTSA

DATE: January 28, 1994

FROM: Steve Williams -- Director, Public Transportation, Mississippi Department of Education

TO: Terry L. Voy -- Consultant, Bureau of School Administration and Accreditation, Iowa Department of Education

TITLE: None

ATTACHMT: Attached to letter dated 5/31/94 from John Womack to Mike Parker (A42; Std. 222; Part 571.3), letter dated 4/18/94 from Mike Parker to Christopher Hart, and letter dated 1/31/94 from Steve Williams to William Moss

TEXT:

A school district in our state has expressed interest in installing four VCR's and TV monitors on a school bus. The equipment would be used to show films relating to drug education and would target long school bus routes. A school district in Arizona h as implemented such a program on one bus and serves as a model for the interest expressed by the district in Mississippi.

The school district proposes to mount the equipment in a school bus equipped with luggage racks. Two units would be mounted in the front of the luggage racks on each side and two in the middle on each side. This provides for maximum visibility of the TV monitor.

We all applaud these efforts to provide an educational opportunity for students that must ride lengthy and time consuming bus routes. However, to my knowledge, there has been no official test conducted to certify the wiring, mounting, and installation o f such equipment. This certainly raises various safety and liability concerns. However, it does not appear to be in conflict with the Federal Motor Vehicle Safety Standard 222, head impact zone.

The 1990 National Standards for School Buses and Operations (NSSBO) appear to most appropriately address this matter. Bus Body Standards - Interior (1), page 16, states in part:

Interior of bus shall be free of all unnecessary projections, which include luggage racks and attendant hand rails, likely to cause injury.

Based on the concerns expressed above, I am requesting an interpretation and/or opinion from the Interpretation Committee on the following questions:

1. Would the installation of VCR's and TV monitors in luggage racks on a school bus be prohibited based on the language of the 1990 NSSBO - Bus Body Standards - Interior (1), page 16.

2. Would the installation of VCR's and TV monitors in luggage racks on a school bus be prohibited based on any other standard included in the 1990 NSSBO.

3. In the committee's opinion, does installation of VCR's and TV

monitors on school buses as described above, violate any Federal Motor Vehicle Safety Standard. Although Federal Motor Vehicle Safety Standards regulate the manufacture and sale of school buses, it is the intent of national and state specifications that users (school districts) not modify or install any component contrary to Federal Motor Vehicle Safety Standards.

I appreciate your assistance and timely consideration of this matter. If you have any question, let me know.