Interpretation ID: nht78-1.38

DATE: 04/25/78

FROM: AUTHOR UNAVAILABLE; J. J. Levin, Jr.; NHTSA

TO: Wayne Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your February 28, 1978, letter asking whether portions 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 the 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,

ATTACH.

PHOTO A VIEW LOOKING FORWARD TOWARD RIGHT-HAND FRONT SERVICE DOOR.

(Graphics omitted)

PHOTO B VIEW LOOKING FORWARD TOWARD LEFT-HAND FRONT DRIVER'S AREA.

(Graphics omitted)

Wayne Corporation

February 28, 1978

Office of Chief Counsel National Highway Traffic Safety Administration

Dear Sir:

This inquiry concerns Federal Motor Vehicle Safety Standard 222, School Bus Passenger Seating and Crash Protection. The enclosed photographs marked and labeled as follows:

Photo A - View looking forward toward right-hand front service door, and Photo B - View looking forward toward left-hand front driver's area, show interior views of the Wayne Busette school bus described in the enclosed Wayne Busette specification sheet. The interior surfaces of the bus colored pink and yellow in Photos A and B fall within the head protection zone defined in FMVSS 222, S5.3.1.1. For purposes of clarity, the front row of passenger seats had been removed before the pictures were taken.

Please advise whether or not the areas colored pink and yellow in Photos A and B are subject to the requirements of FMVSS 222, S5.3.1.2, Head Form Impact Requirements, and S.5.3.1.3, Head Form Force Distribution. In responding to this inquiry, we ask that consideration be given to the first paragraph of S5.3.1.1, "The head protection zones in each vehicle are the spaces in front of each school bus passenger seat which are not occupied by bus sidewall, window, or door structure and which . . . ." Wayne believes that while the pink and yellow colored areas are located in front of a passenger seat, these surfaces should be classified as part of the bus sidewall, window, and door structure and, therefore, are excluded from the requirements of S5.3.1.2 and S5.3.1.3.

Your prompt attention and early reply to this inquiry would be greatly appreciated.

Sincerely yours,

Robert B. Kurre Director of Engineering

[Enclosures Omitted]