Interpretation ID: aiam2428

Mr. L. T. Mitchell, Jr., Engineering Department, Thomas Built Buses, Inc., 1408 Courtesy Road, P. O. Box 2450, High Point, NC 27261; Mr. L. T. Mitchell
Jr.
Engineering Department
Thomas Built Buses
Inc.
1408 Courtesy Road
P. O. Box 2450
High Point
NC 27261;

Dear Mr. Mitchell: This is in response to your letter of September 2, 1976, in which yo ask whether the definition of 'contactable surface' in Standard No. 222, *School Bus Passenger Seating and Crash Protection*, includes areas on the front of the seatback located more than three inches from the top of the seat.; Your interpretation of 'contactable surface' is correct. The standar states in paragraph S4 that only the uppermost three inches of area on the front of the seatback if considered part of the 'contactable surface.' The remainder of the front of the seatback is not considered part of the 'contactable surface' and need not meet the head impact requirements of S5.3.; Sincerely, Frank A. Berndt, Acting Chief Counsel