Interpretation ID: 77-2.6

TYPE: INTERPRETATION-NHTSA

DATE: 04/08/77

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Wayne Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your February 22, 1977, letter asking whether a restraining barrier in front of a seat with a back higher than that required in S5.1.2 of Standard No. 222, School Bus Passenger Seating and Crash Protection, must coincide with or lie outside of the perimeter of the extended seat back.

The requirements for restraining barrier surface area are found in paragraph S5.2.2 of the standard. That section states that: "in a front projected view of the bus, each point of the barrier's perimeter coincides with or lies outside of the perimeter of the seat back of the seat for which it is required." The seat back of the seat for which a restraining barrier is required has dimensions specified in S5.1.2 of the standard. Therefore, a restraining barrier must only coincide with or lie outside of the seat back surface required by S5.1.2. If a seat back surface exceeds the size required in Standard No. 222, the size of the restraining barrier need not coincide.

SINCERELY,

Wayne Corporation

February 22, 1977

Frank R. Berndt Office of Chief Counsel NHTSA

This inquiry is in reference to FMVSS 222, School Bus Passenger Seating and Crash Protection, as applied to school buses with a GVWR of more than 10,000 pounds.

Must the perimeter of a barrier located in front of a seat having a back higher than that required by Section S5.1.2 coincide with or lie outside of the perimeter of the extended seat back?

Your prompt attention to this matter and an early reply will be greatly appreciated.

Robert B. Kurre Director of Engineering