Interpretation ID: nht89-1.32

TYPE: INTERPRETATION-NHTSA

DATE: 03/07/89

FROM: JAMES L. OBERSTAR -- CONGRESS

TO: ERIKA Z. JONES -- CHIEF COUNSEL NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 04/05/89, FROM ERIKA Z. JONES -- NHTSA TO JAMES L. OBERSTAR, REDBOOK A33(2), VSA SECTION 123

TEXT: Dear Ms. Jones:

I am writing on behalf of Mr. Joseph Mikoll of Transportation Equipment Corporation (TEC) of Hopkins, Minnesota, with whom you have previously corresponded regarding passive restraints for school buses of 10,000 GVWR or less.

I have read your opinion that installation of TEC's "safety bar devices could not be in place of seat belts and still meet crash protection requirements set forth in Standard No. 222.

I am writing to request answers to two additional points.

1.) Is there a procedure that TEC could follow to request a waiver of the provisions of Standard No. 222 which would allow its safety bar devices to be the sole passive restraint on small buses?

2.) Are there DOT funds available to firms such as TEC to do rigorous testing and R&D on passive restraint devices?

Any light you can shed on this situation would be greatly appreciated. Please respond to my Duluth District Office.

Sincerely,