Interpretation ID: 7378
Vice President
School Bus Manufacturers Institute
7508 Ben Avon Road
Bethesda, MD 20817
Dear Mr. Sweet:
This responds to your letter of May 29, 1992 asking what minimum passenger size (weight and height) was used in developing the requirements of Federal Motor Vehicle Safety Standard No. 222, School Bus Passenger Seating and Crash Protection. You noted that several school districts are now transporting newborn and under-school-age children to schools which provide day-care service, and that you have received inquiries concerning the "limits, if any, on passenger size and age that can be safely transported on school bus seats."
The National Traffic and Motor Vehicle Safety Act, defines a "school bus" as a vehicle that "is likely to be significantly used for the purposes of transporting primary, preprimary, or secondary school students to or from such schools or events related to such schools." NHTSA has never specified a passenger size and/or age range applicable to the compartmentalized school bus seats required by Standard No. 222. In developing the standard, however, NHTSA considered the range of sizes and ages of children attending preprimary through secondary school.
NHTSA has developed approximate size and weight guidelines for child restraint systems. For children from birth to 9-12 months (or up to 20 pounds), NHTSA recommends use of an infant or convertible seat facing the rear. For children from 9-12 months to 4 years (or 20 pounds to 40 pounds), NHTSA recommends use of a convertible or toddler seat. If a school is transporting children in these age and weight ranges, they may want to consider using a school bus with safety belts to secure a child restraint system. I have enclosed a consumer information sheet titled "Transporting Your Children Safely" for your information.
I hope you find this information helpful. If you have any other questions, please contact Mary Versailles of my staff at this address or by phone at (202) 366-2992.
Sincerely,
Paul Jackson Rice Chief Counsel
Enclosure
ref:571 d:7/28/92