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Interpretation ID: 7379

Mr. Mark W. Russo
1480 West Macopin Road
West Milford, NJ 07480

Dear Mr. Russo:

This responds to your letter of May 27, 1992, to Mr. Charles Gauthier of this agency, which enclosed a copy of R-Bar test data provided by Micho Industries. You requested an "official `review and comment'" regarding the applicability of Safety Standard 222 to the R-Bar Passenger Restraint System and related issues.

The National Highway Traffic Safety Administration (NHTSA) has addressed the use of "safety bars" in school buses on several occasions in the past. Enclosed for your information are copies of five NHTSA letters which address this subject and which, we believe, will also address your concerns. The letters are addressed to Mr. Michael F. Hecker of Micho Industries, dated May 14, 1992; Mr. Scott K. Hiler of the C. E. White Company, dated January 31, 1991; Honorable Robert J. Lagomarsino, Member of Congress, dated January 8, 1990; and Mr. Joseph F. Mikoll of Transportation Equipment Corporation, dated March 10, 1989 and November 3, 1988.

If, after reviewing the enclosed materials, you still have questions concerning this matter, please feel free to contact Mr. Walter Myers of my staff at this address or at (202) 366- 2992.

Sincerely,

Paul Jackson Rice Chief Counsel

Enclosures Ref: #222 d:7/l3/92