Interpretation ID: nht81-2.29

DATE: 05/27/81

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Thomas Built Buses, Inc.

TITLE: FMVSS INTERPRETATION

TEXT:

MAY 27 1981

NOA-30

Mr. Jim Tydings Thomas Built Buses, Inc. 1408 Courtesy Road P.O. Box 2450 High Point, North Carolina 27261

Dear Mr. Tydings:

This responds to your April 14, 1981, letter asking whether a fold-up seat that you plan to build in a school bus would comply with the Federal motor vehicle safety standards.

You state in your letter that the seat would comply with all of the requirements of Standard No. 222, School Bus Passenger Seating and Crash Protection. If the seat complies with that standard and if its location in the bus will not interfere with the requirements applicable to emergency exits, then the seat should comply with all of the Federal safety standards.

Sincerely,

Frank Berndt Chief Counsel

April 14, 1981

Office of the Chief Counsel U.S. Department of Transportation 400 S.W. 7th St. Washington, D.C. 20590

Attn: Mr. Roger Tilton

Subject: FMVSS 217-76, Bus Window Retention and Release

Dear Mr. Tilton:

Enclosed is our print #46-009627, Sketch - Fold Up Seat Cushion at Emergency Exit, plus photos.

This print shows a side (left) emergency exit and the location of a seat wherein the cushion is spring loaded to maintain the cushion in an upright position when the seat is unoccupied.

The advantage being that this seat configuration provides greater egress to the side door. This seat naturally would meet all requirements of FMVSS-222 School Bus Passenger Seating and Crash Protection.

It is our opinion that this arrangement meets the applicable Federal Motor Vehicle Standards.

We would appreciate it if you would review this material and advise us of your conclusions.

Thanking you in advance, I remain

Sincerely,

THOMAS BUILT BUSES, INC.

Jim Tydings, Specifications Engineer

JT/jf

Enclosure