Interpretation ID: nht92-3.15

DATE: 10/16/92

FROM: SHIRLEY A. STEWART -- PRESIDENT, SAS ELECTRICAL SERVICE, INC.

TO: CHIEF COUNSEL, NHTSA

ATTACHMT: ATTACHED TO LETTER DATED 11-17-92 FROM PAUL J. RICE TO SHIRLEY A. STEWART (STD. 201; STD. 208; STD. 221; STD. 222; A40)

TEXT: In reference to an October 2nd meeting that I had with Messrs. Maurice Hicks and Rich Vaniderstine, Safety Standard Engineers, I presented a video tape on the installation of the silent monitor being installed on school buses. I also had a demo silent monitor box. We are requesting the federal motor vehicle safety standards interpretation on how those standards are applied for installation on school buses.

The silent monitor is a metal box designed to house a video camera to monitor the interior of school buses but can be used in hallways and classrooms. It is mounted by two angle brackets after cutting a 6 1/2" x 6 1/4" hole in the interior access door. The silent monitor box (6 x 6 x 6) is installed in the bus access door and will only protrude toward the interior of the bus 3 - 4 inches. The silent monitor is designed in a manner that keeps drivers and students from knowing if a video camera is in the locked box. The installer will use No. 10 x 1/2" self-drilling screws provided with the box and brackets to attach brackets to the access door and then install the camcorder into the box and focus the picture to the height of the words located in the rear of the bus that says, "emergency exit". The installer will then install the self-drilling screws in the silent monitor box and to the access door and the installation is complete.

The glass on our box is a reflective solar cool glass. This breaks the glare inside the box. The silent monitor box is 16 gauge, welded steel. Our box is designed to be tamper-proof and for safety. The lock is a 5-tumbler, brass lock for durability.

Enclosed are specifications and instructions for installation. Enclosed also is a picture that was taken on October 15th, on a Prince George's County school bus.

If there are any questions, please contact me at (703) 471-1450. (GRAPHICS OMITTED.)