Interpretation ID: nht93-4.17

DATE: June 3, 1993

FROM: Michael H. Dunn -- Vice President, Marketing, Micho Industries

TO: Greg Fera -- Pupil Transportation Specialist, Department of Education, Bureau of Pupil Transportation

COPYEE: M. Hecker; J. Heritscko; G. Gruber

TITLE: Re: R-Bar Passenger Restraint System

ATTACHMT: Attached to letter dated 6-29-93 from John Womack to Michael H. Dunn (A41; Std. 222); Also attached to letter dated 11-29-91 from Paul Jackson Rice to Michael H. Dunn; Also attached to letter dated 12-3-91 from Michael H. Dunn to Paul Jackson Rice.

TEXT: To confirm our recent telephone conversation, Micho Industries is now making the arrangements to complete the testing of the R-Bar, with the latest modifications, for compliance with FMVSS 222, specifically for rear impact (4" clearance) requirements.

This testing should put to rest the only remaining concern about the safety of the R-Bar and its compliance with all applicable Federal standards, since all other aspects of those regulations have previously been tested and "certified" to meet those requirements.

We hope to have the complete test data package very soon and I will forward a copy to you immediately for evaluation. In the meantime, please don't hesitate to call me if you have any questions.

May 17, l993

Mr. Greg Fera, Pupil Transportation Specialist Department of Education Bureau of Pupil Transportation, CN-500 225 W. State Street Trenton, NJ 08625-0500

Re: R-Bar Passenger Restraint System

Dear Greg:

To confirm our telephone conversation, I wish to advise you that, due to several improvements made in the R-Bar design, we can not "CERTIFY" that it is in full compliance with all requirements of FMVSS No. 222, including the rear impact tests described in S5.1.4(c) of that regulation. Please advise Linda Wells for me and, if either of you have any questions, please let me know.

As you know, it is the responsibility of the manufacturer of a product to provide that certification and Micho Industries can now offer you that assurance.

While details of specific changes will not be made public for awhile, I wanted you to be one of the first to be aware of the fact that we can now offer the R-Bar for sale in New Jersey and other states that are looking for a practical and safe alternative to seat belts for school buses.

Thanks for your patience with us. I am sorry it took to so long to get here.

Regards,

Michael H. Dunn V.P. Marketing

MHD/md CC: M. Hecker, J. Heritscko, G. Gruber