Interpretation ID: nht88-1.67

TYPE: INTERPRETATION-NHTSA

DATE: 03/10/88

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Rusty Mitchell -- A-Z Bus Sales, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: Rusty Mitchell A-Z Bus Sales, Inc. P.O. Box 9389 5555 W. Mission Blvd. Ontario, CA 91762

This is a response to your letter of November 11, 1987, in which you asked for information on the "application of seat belts in school buses." I am pleased to have this opportunity to explain our regulations to you.

The National Highway Traffic Safety Administration (NHTSA) is responsible for developing safety standards applicable to all new motor vehicles, including school buses. In 1977, we issued a set of motor vehicle safety standards regulating various aspects of school bus performance. Among those standards is Standard 222, School Bus Passenger Seating and Crash Protection. Standard 222 requires large school buses (those with a gross vehicle weight rating over 10,000 pounds) to afford passe or crash protectio n by means of "compartmentalization."

Compartmentalization requires large school buses to incorporate certain protective elements into the vehicles interior construction, thereby reducing the risk of injury to school bus passengers without the need for safety belts. These elements include hi gh seats with heavily padded backs and improved seat spacing and performance.

Our regulations require a safety belt for the school bus driver because the driver's position is not compartmentalized. Further, because small school buses (10,000 pounds or less GVWR) experience greater force levels in a crash, Standard 222 requires the added protection of safety belts at each passenger position in a small school bus.

School buses continue to have one of the lowest fatality rates for any class of motor vehicle. Large school buses are among the safest motor vehicles because of their size and weight (which generally reduce an occupant's exposure to injury-threatening cr ash forces), the drivers' training and experience, and the extra care other motorists usually take when they are near a school bus. For these reasons, our regulations do not require safety belts for passengers in large school buses.

I enclose a copy of a June 1985 NHTSA publication titled "Safety Belts in School Buses," which discusses many of the issues relative to this subject.

You also asked whether there is an order form listing available data for safety belts in school buses. This agency does not publish "order forms" for any data. For further information on this subject, you may wish to contact individual school bus manufac turers to ask for data about safety belts in their buses. I hope you find this information helpful.

Sincerely,

Erika Z. Jones Chief Counsel

Enclosure

November 11, 1987

Ms. Erika Z. Jones National Highway Traffic Safety Administration 400 7th Street S.W. Washington. D.C. 20590

Ms. Jones:

We need information regarding the application of seat belts in school buses.

Is there an order form with a listing or all data available if so, who do we contact, and can we order several copies of each?

Ms. Jones, any information you can send us would be greatly appreciated.

Thank You,

Rusty Mitchell Sales Representative

RM/df