Interpretation ID: aiam2798
Wayne Corporation
P.O. Box 1447
Industries Road
Richmond
IN 47374;
Dear Mr. Kurre: This responds to your February 28, 1978, letter asking whether portion of your van-type school bus have to comply with the head protection zone requirements of Standard No. 222, *School Bus Passenger Seating and Crash Protection*. You enclosed pictures showing portions of the bus designated in pink and yellow and question the standard's applicability to them.; The head protection zone requirements do not apply to portions of th school bus that are considered part of the bus sidewall. The National Highway Traffic Safety Administration considers the sidewall to include those surfaces that run parallel to the outboard edge of a forward facing seat. Accordingly, the portions of your bus designated in yellow in the pictures need not comply with the requirements since they are part of the bus sidewall structure. The pink portions of your photographs represent part of the bus structure that is perpendicular to the bus sidewall. The NHTSA does not consider them to be part of the bus sidewall structure. Therefore, since they fall within the head protection zone they must comply with all of the requirements applicable to that zone.; Sincerely, Joseph J. Levin, Jr., Chief Counsel