Interpretation ID: aiam2660
The Coachette Company
P.O. Box 1427
Highway 65 South
Conway
AR 72032;
Dear Mr. Ryan: This responds to your August 18, 1977, letter asking whether the hea protection zone requirements of Standard No. 222, *School Bus Passenger Seating and Crash Protection*, apply to a portion of your bus located directly above the side windows.; You enclosed a sketch which details the bus sidewall and roo structure. On that sketch, you have shaded a small area asking whether that portion of the bus constitutes part of the bus sidewall or part of the roof structure. The head protection zone requirements of the standard (S5.3.1.1) do not apply to the sidewalls of school buses.; The National Highway Traffic Safety Administration (NHTSA) interpret your sketch to show the sidewall ending and the roof structure beginning at the point where the radius of curvature of the interior structure decreases sharply (see the point marked 'A' on the sketch). Since the shaded portion of your sketch falls below that point, it is considered part of the sidewall and need not comply with the head protection zone requirements.; Sincerely, Joseph J. Levin, Jr., Chief Counsel