ID: nht92-2.4

DATE: 11/25/92

FROM: PAUL JACKSON RICE -- CHIEF COUNSEL, NHTSA

TO: KEVIN MITCHELL -- GOODYEAR TIRE & RUBBER CO.

ATTACHMT: ATTACHED TO LETTER DATED 9-21-92 FROM KEVIN MITCHELL TO PAUL J. RICE (OCC 7759)

TEXT: This responds to your letter asking about the hydraulic brake hose labeling requirements (S5.2) of FMVSS 106, Brake Hoses. You indicated that your current brake hoses have two stripes, on opposite sides of the hose. Each of the stripes is interrupted by a line of information. One line, which you call the "DOT print line," contains the information required by FMVSS 106. The other line, which you call the "SAE print line," contains certain information not required by FMVSS 106, including "batch and shift" information.

You asked whether it is permissible to place the batch and shift information (consisting of a mark such as "AA") on the DOT print line. You stated that moving the batch and shift mark to the DOT print line would improve the legibility of the SAE print line. This is because better print materials could be used in the SAE print line if that legend did not contain a mark that must be updated on a daily or more frequent basis, such as the batch and shift mark. As discussed below, the batch and shift information may not be placed on the same line as the required information.

NHTSA's longstanding position, stated in past rulemaking notice preambles (e.g., 39 FR 7425, February 26, 1974; 39 FR 24012, June 28, 1974), is that the DOT print line may only contain the required information. The striping requirement (S5.2.1) of FMVSS 106 states that one of the requisite stripes on a brake hose "may be interrupted by the information required by S5.2.2, and the other stripe may be interrupted by additional information at the manufacturer's option." We interpret this to mean that the stripe that is interrupted by the required information may not be interrupted by information voluntarily provided by the manufacturer. This conclusion is consistent with the preamble for the final rule establishing S5.2.1 (38 FR 31302, November 13, 1973), which refers to optional additional information as not being permitted in the legend that interrupts the first stripe. (That rule modified the labeling requirements to permit interruption of the second stripe with the optional information.) NHTSA did not permit optional information to be mixed with the required information because the mixture of optional and required labeling could obscure or confuse the meaning of the required information, or interfere with the appearance of complete labeling on some hose assemblies.

For your information, we have enclosed the Federal Register documents cited above. Please contact Ms. Fujita of my staff at (202) 366-2992 if you have any further questions.

ID: nht92-2.40

DATE: 11/09/92

FROM: PAUL JACKSON RICE -- CHIEF COUNSEL, NHTSA

TO: CHRISTOPHER LEONE -- NEWBOLD DESIGNS

ATTACHMT: ATTACHED TO LETTER DATED 8-6-92 FROM CHRISTOPHER LEONE TO TAYLOR VINSON

TEXT: This responds to your FAX of August 6, 1992, to Taylor Vinson of this Office, asking for rules and regulations of the Department on electric vehicles. I understand that you talked with Mr. Vinson later in the day, and received an overview of the matter. I further understand that you intend only the construction of a single experimental vehicle, and have no plans for its production.

Under the National Traffic and Motor Vehicle Safety Act, the introduction into interstate commerce, by any person, of a motor vehicle that does not conform to all applicable Federal motor vehicle safety standards is a violation, for which a civil penalty of up to $ 1,00 may be imposed. The Federal motor vehicle safety standards are set out in Title 49 Code of Federal Regulations Part 571. There are no standards that apply to your project car are those that apply to "passenger cars" in general.

However, the manufacturer of an electric vehicle may petition us for a temporary exemption (up to 2 years) from one or more of the safety standards on the basis that the exemption would facilitate the development and field evaluation of a low-emission motor vehicle. The temporary exemption regulations are found at 49 CFR Part 555. An exemption covers up to 2,500 vehicles per year for any 12-month period that the exemption is in effect.

Regulations governing the licensing of motor vehicles are the prerogative of the individual States. Thus, you should inquire as to what Rhode Island requires for your contemplated vehicle.

There is a regulatory gap which your situation highlights, and that is the legal status of a person who intends to build only a single motor vehicle. Such a person is not a "manufacturer" under the Act, since the operative portion of the definition of "manufacturer" is one who manufactures or assembles "motor vehicles". The temporary exemption authority appears directed towards commercial enterprises and not single motor vehicles. Nevertheless, we believe we have the authority to exempt a single motor vehicle under these provisions.

If you wish to consult us further in this matter, Taylor Vinson will be pleased to help you.

ID: nht92-2.41

DATE: 11/09/92

FROM: MARION C. BLAKEY ADMINISTRATOR, NHTSA

TO: HONORABLE JOHN D. DINGELL -- CHAIRMAN, COMMITTEE ON ENERGY AND COMMERCE, U.S. HOUSE OF REPRESENTATIVES

COPYEE: MR. AARON GORDON

ATTACHMT: ATTACHED TO LETTER DATED 9-17-92 FROM JOHN D. DINGELL TO MARION C. BLAKEY

TEXT: Thank you for your letter of September 17, 1992, enclosing correspondence from Mr. Aaron Gordon concerning seat belts on school buses. You requested comments on Mr. Gordon's letter and on H.R. 896, a bill referred to in Mr. Gordon's letter.

The issue of safety belts on school buses is an important topic which the National Highway Traffic Safety Administration (NHTSA) has thoroughly studied for many years. School bus transportation has been and continues to be one of the safest forms of transportation in America. Every year, approximately 370,000 public school buses travel approximately 3.5 billion miles to transport 22 million children to and from school and school-related activities. Since NHTSA began tracking traffic fatalities in 1975, an average of 16 school bus occupants per year have sustained fatal injuries. While each of these fatalities is tragic, the number of school bus occupant fatalitie is small compared to the number of occupant fatalities to children in other types of vehicles. For example, in 1989 there were 5,287 deaths among children aged five to 18 in vehicles other than school buses.

In 1977, NHTSA issued Federal motor vehicle safety standard No. 222, School Bus Passenger Seating and Crash Protection, which established minimum crash protection levels for occupants of all school buses. For large school buses, those with a gross vehicle weight rating (GVWR) above 10,000 pounds, the standard requires occupant protection through a concept called "compartmentalization" -- strong, well-padded, well-anchored, high-backed, evenly spaced seats. The effectiveness of "compartmentalization" has been confirmed by independent studies by the National Transportation Safety Board (NTSB) and the National Academy of Sciences (NAS). Under the current requirements of Standard No. 222, small school buses, those with a GVWR of 10,000 pounds or less, must provide "compartmentalization" and be equipped with lap or lap/shoulder belts at all designated passenger seating positions. The agency believes that safety belts are necessary in addition to "compartmentalization" in small school buses because of their smaller size and weight, which are closer to that of passenger cars and light trucks.

In 1987, the NTSB completed a study of the crashworthiness of large school buses, and concluded that most school bus occupant fatalities and serious injuries were "attributable to the occupants' seating position being in direct line with the crash forces. It is unlikely that the availability of any type of restraint would have improved their injury outcome."

In 1989, NAS completed a study of means to improve school bus safety and concluded that "the overall potential benefits of requiring seat belts on large school buses are insufficient to justify a Federal requirement for mandatory installation. The funds used to purchase and maintain seat belts might better be spent on other school bus safety programs and devices that could save more lives and reduce more injuries." The NAS pointed out that since children are at greater risk of being killed in school bus loading zones (i.e., boarding and leaving the bus) than on board school buses, "a larger share of the school bus safety effort should be directed to improving the safety of bus loading zones." A summary of the NAS report is enclosed.

In response to the recommendations from the NAS study, NHTSA has initiated several rulemaking actions, such as improvements to school bus visibility by the driver and requiring stop signal arms on school buses, designed to improve the safety of students in school bus loading zones. Besides the actions taken in response to the NAS study, NHTSA has initiated several other rulemaking activities to improve further the safety of school buses, e.g., increasing the number of emergency exits, establishing wheelchair securement/occupant restraint requirements, and improving the body joint strength requirements.

While there are no Federal requirements for safety belts on large school buses, states are free to install them if they feel it is in the best interest in their state. However, as noted in the NAS report, if the safety belts are to be beneficial, "states and local school districts that require seat belts on school buses must ensure not only that all school bus passengers wear the belts, but that they wear them correctly."

In summary, the safety record of school buses is outstanding. As such, there is no compelling evidence to suggest that safety belts would provide even higher levels of occupant crash protection. Also, the agency agrees with the conclusion from the NAS report, that there is insufficient reason for a Federal mandate for safety belts on large school buses.

I hope you find this information helpful.

ATTACHMENT TRB REPORT SUMMARY, DATED MAY, 1989, ENTITLED SPECIAL REPORT 222-IMPROVING SCHOOL BUS SAFETY. (TEST OMITED)

ID: nht92-2.42

DATE: November 9, 1992

FROM: Rodney T. Nash -- Vice President Engineering, Collins Industries, Inc.

TO: Administrator, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 12/30/92 from Stephen P. Wood (signed by John Womack) (A40; Part 571.3)

TEXT:

Please forward this letter to the appropriate locations within the office of General Counsel to answer this question on vehicle designation. The final-stage manufacturer of a vehicle is required to label his vehicle with the information designated in FMVSS 115 and FMVSS 120. This information requires the final-stage manufacturer to designate the vehicle classification involved. We need to know how to classify an ambulance that is built on a truck chassis.

The ambulance carries more weight of specialized equipment for patient-care support than it carries people. The special purpose vehicles operates half of its life with no patient in the rear cargo area but always carries heart monitors, jaws of life, stretchers, respirators, and other life-support equipment. The question that needs clarification is what vehicle class (truck or MPV) should be applied to an ambulance. Should the classification change if the vehicle is focused on equipment transport over patient transport? It appears to us that the final-stage manufacturer is free to select between these categories.

Should you wish to discuss this question further, please call 316-663-5551 during normal working hours. I've taken the liberty of enclosing a piece of sales literature for a cargo intensive ambulance for you to review in issuing your opinion letter.

Thank you in advance for any prompt consideration you can give this request.

ID: nht92-2.43

DATE: 11/07/92

FROM: JORDAN J. POKRINCHAK -- PRESIDENT, JORDAN RESEARCH CORPORATION

TO: PAUL JACKSON RICE -- CHIEF COUNCIL D.O.T.

ATTACHMT: ATTACHED TO LETTER DATED 12-4-92 FROM STEPHEN P. WOOD TO JORDON J. POKRINCHAK (A40; STD. 108); ALSO ATTACHED TO NHTSA LETTER OF 3-26-92 TO CHARLES W. O'CONNOR

TEXT: I am writing to you in regard to your recent decision to approve electronic brake controls made by Tekonsha Engineering Company in relation to stop lamp operation when braking with a trailer in tow.

I would cite Section 393.25 Paragraph (F) "Stop Lamp Operation," of Code of Federal Regulations Volume 49 (Transportation Parts 400 to 999) Revised as of October 1, 1989, for the basis of my concern as to the operation of the stop lamps when applying the trailer brakes in an emergency condition.

I believe this section of the code is quite specific when dealing with the actuation of the trailer stop lamps, either manually or automatically, and has nothing to do with the installation of controllers in regard to rendering the stop lamps inoperative in whole or in part within the meaning of Section 1397 (a) (2) (A) of 15 U.S.C. which you have cited in rendering your decision.

I also believe that in all laws and regulations, there is the letter of the law, and the intent of the law which must be considered when rendering such an important decision as you have on Tekonsha Brake Controls and its effect on the general driving public.

Tekonsha Engineering has had problems with the operation of their brake controls for some time. One way of alleviating the problem was to remove the wire that activated the control through the tow vehicle stop-light switch and which in turn operated the stop lamps on the trailer being towed. By eliminating this feature of activating the trailer stop lamps in the manual mode, they have placed the operator of the vehicle towing the trailer at risk for a rear end collision. While he (the operator) may have knowingly rendered the stop lamps on the towed vehicle inoperative for the duration of such activation of the hand control (manual mode) as stated in your decision, the driver behind the trailer has not been given any warning that the brakes on the trailer are being applied.

Tekonsha Engineering has cited your decision in regard to Section 1397 (a) (2) (A) with all due pomp and circumstance, but has failed to comply with common sense in regard to avoiding accidents. You have in effect given them the "green light" to produce their "Voyager" and "Commander" brake controls without regard to driver safety.

I believe you should reconsider all the facts in rendering your decision on the basis of driver safety and not some regulation that Tekonsha Engineering is using out of context. We do, Gentlemen, look to you for decisions that will protect lives on our highways.

You have it within your power to require Tekonsha Engineering to comply with regulations pertaining to the operation of trailer stop lamps by simply requiring that they (Tekonsha Engineering) add the wire or connection to their controls that would activate the trailer stop lamps in the manual mode. After all, they are the only manufacturer of trailer brake controls that do not activate the trailer stop lamps in the manual mode and are using you to help market a potentially dangerous product.

ID: nht92-2.44

DATE: 11/06/92

FROM: RICHARD HORIAN -- PRESIDENT, WOODLEAF CORP.

TO: PAUL J. RICE -- CHIEF COUNSEL, NHTSA

TITLE: SUDDEN BRAKE INDICATOR HAZARD LIGHT

ATTACHMT: ATTACHED TO LETTER DATED 12-7-92 FROM PAUL J. RICE TO RICHARD HORIAN (A40; STD. 108)

TEXT: Enclosed is an official request for proposal to allow a vehicular lighting system that warns when an emergency braking situation or other hazard is occurring. Simply, when a driver engages in hard braking, a circuit activates a separate lighting system to warn other drivers to pay special attention to a potentially hazardous situation.

The Sudden Brake Indicator Hazard Light is different from other similar systems proposed over the years with the following unique advantages:

(A) An electronic pressure switch is used within the brake pedal assembly. No hydraulic pressure switch is mounted within the vehicle's hydraulic brake lines. If the electric pressure switch fails for any reason, all existing braking and lighting systems on the vehicle remain unaffected.

(B) Increased foot pressure being applied during hazard braking conditions is a natural ergonomic reflex. The driver does not have to divert his attention to activate a manual switch or other device.

(C) The Sudden Brake Indicator Hazard Light may be activated when the vehicle is not in motion. Most rear end collisions occur when the lead vehicle is stopped. If the stopped lead vehicle driver notices in his rear view mirror that another driver is approaching too fast, he simply has to depress his brake pedal with greater pressure to instantly activate the hazard light. No time is lost as the driver's foot is already on the brake.

(D) In emergency situations when a vehicle goes off the road and comes to a stop, the hazard light may be instantly activated by harder depression of the brake pedal. This is primarily important during night time freeway driving. Precious seconds are not lost while searching for the manually activated hazard light switch until it is turned on.

(E) Most importantly, there is no chance of drivers becoming desensitized to the Sudden Brake Indicator Hazard Light as it is rarely used. Other proposed systems were designed to be activated during all braking conditions. With these systems, either flashing or steady burning, this is tantamount to just another brake light that sooner or later would be regarded the same as existing brake light designs.

ATTACHMENT

Mr. Paul J. Rice Chief Counsel National Highway Traffic & Safety Administration 400 7TH Street, Room 5219 Washington, DC 20590

REFERENCE: SUDDEN BRAKE INDICATOR HAZARD LIGHT

Dear Mr. Rice,

Please allow a written opinion for allowance of a Sudden Brake Indicator vehicular hazard lighting system described as follows.

A separate hazard brake light system that is activated only when a predetermined threshold of pressure is reached upon physical depression of a vehicle's brake pedal. The hazard brake light system primarily consists of two components: (A) A pressure sensitive electronic switch mounted within the vehicle's brake pedal assembly that is activated only when a predetermined amount of foot pressure is applied to the brake pedal that is usually greater than those pressures applied during normal driving conditions (as an example, foot pressure application greater than 25 lbs. of force). (B) A light or light assembly that is mounted to the rear of the vehicle that when illuminated, may warn other vehicles of a sudden braking or other hazard situation.

The hazard light may be red or amber in color and steady burning or flashing as required to warn other drivers that a hazard situation may be occurring so that special driving attention should be employed.

The hazard brake light system will be mounted in one of two places. (A) The high mount stop light outer housing will be slightly expanded to contain a separate inner housing or housings with separate bulb and lens coverings from that of the high mount stop light. (B) Elsewhere on the rear of the vehicle so as not to conflict with the other lighting functions mandatory on the vehicle.

The switch, hardware, wiring, lights, lenses and housings will conform to all existing Automotive Codes of Federal Regulations. The hazard light system will be design manufactured and installed for use only on original equipment manufactured vehicles.

Sincerely,

Richard Horian

President

ID: nht92-2.45

DATE: 11/05/92

FROM: KIM WELSH -- EMMETT KOELSCH COACHES

TO: PUBLICATIONS DEPARTMENT, DOT

ATTACHMT: ATTACHED TO LETTER DATED 12-1-92 (EST.) FROM PAUL J. RICE TO KIM WELSH (A40; PART 571.3)

TEXT: Please forward a copy of the "Motor Vehicle Safety Standards" regarding School Buses and other Transit type vehicles. Please use the above address. If there are any questions please use our number list above.

Thank You!

ID: nht92-2.46

DATE: 11/03/92

FROM: PAUL JACKSON RICE -- CHIEF COUNSEL, NHTSA

TO: JAMES A. WESTPHAL -- OSHKOSH CHASSIS DIVISION, OSHKOSH TRUCK CORPORATION

ATTACHMT: ATTACHED TO LETTER DATED 9-2-92 FROM JAMES A. WESTPHAL, OSHKOSH, TO NHTSA ADMINISTRATOR (OCC 7745)

TEXT: This letter responds to your inquiry about which Federal Motor Vehicle Safety Standards would be applicable to certain incomplete vehicles (chassis less cab) that you manufacture for motor homes. You anticipate that the motor homes will have a gross vehicle weight rating (GVWR) over 10,000 pounds but less than 26,000 pounds.

Your letter indicated that Oshkosh plans to install brake systems in the two models which use compressed air to provide braking power, and hydraulic fluid to transmit the energy to the hydraulically activated disc brakes at each wheel. You stated that this system is commonly known as "air-over-hydraulic."

The following is in response to your four specific questions:

1. Must the brake system comply with the requirements of Standard No. 121 applicable to trucks?

The answer to question number one is yes. The agency classifies air-over-hydraulic brake systems as air brake systems. Accordingly, vehicles equipped with air-over-hydraulic brake systems are required to comply with the requirements of Standard No. 121. I am enclosing a July 20, 1984 interpretation letter to Ms. Margaret Moore Oba which discusses this issue at length.

2. Must the brake system comply with the requirements of Standard No. 105 applicable to multipurpose passenger vehicles?

The answer to question number two is no. Standard No. 105 only applies to vehicles with hydraulic brake systems. Since your system is air-over-hydraulic, it is considered to be an air brake system and not a hydraulic brake system.

3. If Standard No. 121 compliance is required must the hydraulically powered disc brakes comply with Section S5.4 Service brake system -- dynamometer tests?

The answer to question number three is yes. The requirements of S5.4 are among the requirements specified in Standard No. 121 for each vehicle equipped with air brakes.

4. If compliance to parts of both Standards 121 and 105 is required, must the system meet the requirements of the following sections in Standard No. 105: S5.1.2 Partial Failure, S5.1.3 Inoperative brake power assist or brake power unit, and/or S5.3 Brake system indicator lamp.

As indicated above, air-over hydraulic brake systems are not required to meet the requirements of Standard No. 105.

I hope this information is helpful. If you have any further questions about NHTSA's safety standards, please feel free to contact Marvin Shaw of my staff at this address or by telephone at (202) 366-2992.

ID: nht92-2.47

DATE: 11/03/92

FROM: PAUL JACKSON RICE -- CHIEF COUNSEL, NHTSA

TO: JULIA WALL -- HEAD OF SCHOOL, THE TRINITY SCHOOL OF TEXAS

ATTACHMT: ATTACHED TO LETTER DATED 09-01-92 (EST.) FROM JULIA WALL TO D.O.T. (OCC 7738)

TEXT: This responds to your letter to the Department of Transportation seeking a copy of the federal law regulating student transportation in general, and as it specifically relates to multiple passenger vans. I assume that your use of the term multiple passenger vans refers to vans with seats to the rear of the driver.

I am pleased to have this opportunity to clarify Federal law as it relates to school buses. By way of background information, NHTSA has the authority under the National Traffic and Motor Vehicle Safety Act to issue motor vehicle safety standards that apply to the manufacture and sale of new motor vehicles, in order to reduce the number of fatalities and injuries that result from motor vehicle crashes.

Under NHTSA's regulations, passenger vans are generally classified as either multipurpose passenger vehicles (MPV's) or buses. The MPV category includes passenger vans which carry ten persons or less; passenger vans which carry more than ten persons are buses. Under the agency's definitions, a "school bus" is a type of bus sold for transporting students to and from school or school-related events.

All MPV's and buses are required to meet Federal motor vehicle safety standards. However, in the legislative history of the School Bus Safety Amendments of 1974, Congress stated that school transportation should be held to the highest level of safety. Accordingly, NHTSA has issued special Federal motor vehicle safety standards applicable to all new school buses.

Like all safety standards, NHTSA's school bus standards impose obligations on the manufacturers and sellers of new motor vehicles, not upon the subsequent users of these vehicles. It is a violation of Federal law for any person to sell any new vehicle that does not comply with all school bus safety standards if the vehicle capacity is more than 10 persons, and if the seller is aware that the purchaser intends to use the vehicle as a school bus. On the other hand, without violating any provision of Federal law, a school may use a vehicle which does not comply with Federal school bus regulations to transport school children. This is so because the individual States, not the Federal government, have authority over the use of vehicles.

However, I would like to call your attention to a guideline that NHTSA has issued under the authority of the Highway Safety Act of 1966. That Act authorizes the agency to issue guidelines for states to use in developing their highway safety programs. NHTSA issued Highway Safety Program Guideline 17, Pupil Transportation Safety, to provide recommendations to the states on various operational aspects of their school bus and pupil transportation safety programs. Guideline 17 recommends that any vehicle designed for carrying more than 10 persons which is used as a school bus comply with all safety standards applicable to school buses at the time the vehicle was manufactured. A copy of Guideline 17 is enclosed.

In conclusion, it is not a violation of Federal law for your school to use vans for transportation of school children; however, use of these vehicles may be restricted by Texas law. I must emphasize NHTSA's position that a vehicle meeting Federal school bus regulations is the safest way to transport students. I strongly recommend that you give your most careful consideration to the possible consequences of transporting school children in vehicles that do not comply with those standards.

I hope this information will be helpful to you. If you have any further questions regarding this matter, please feel free to contact Walter Myers of this office at this address or by telephone at (202) 366-2992.

ID: nht92-2.48

DATE: 11/03/92

FROM: PAUL JACKSON RICE -- CHIEF COUNSEL, NHTSA

TO: G. THOMAS OWENS -- SENIOR ENGINEERING REPRESENTATIVE, AETNA

ATTACHMT: ATTACHED TO LETTER DATED 9-9-92 FROM G. THOMAS OWENS TO OFFICE OF THE CHIEF COUNSEL, NHTSA (OCC 7764)

TEXT: This responds to your letter requesting information regarding the legal aspects of school bus safety standards. Specifically, you requested a book or pamphlet containing the requested information.

By way of background information, under the provisions of the National "Traffic and Motor Vehicle Safety Act of 1966, 15 U.S.C. 1381 et seq. (Safety Act), the National Highway Traffic Safety Administration (NHTSA) is authorized to promulgate Federal motor vehicle safety standards that apply to the manufacture and sale of new motor vehicles, in order to reduce the number of fatalities and injuries that result from motor vehicle crashes. In 1974 Congress enacted the Motor Vehicle and Schoolbus Safety Amendments of 1974 which, by amending section 121 of the Safety Act, directed the issuance of motor vehicle safety standards on specific aspects of school bus safety, applicable to all school buses. Those standards became effective on April 1, 1977 and are included, along with the rest of the agency's safety standards, in 49 CFR Part 571.

The Safety Act defines a school bus as a vehicle that "is likely to be significantly used for the purpose of transporting primary, preprimary, or secondary school students to or from such schools or events related to such schools." NHTSA further defines a school bus as a motor vehicle designed for carrying eleven or more persons, including the driver, and sold for transporting students to and from school or school-related events. See 49 CFR 571.3.

It is a violation of Federal law for any person knowingly to sell as a school bus any new vehicle that does not comply with all applicable Federal school bus safety standards. On the other hand, once a vehicle has been sold to the first purchaser for purposes other than resale, it may be used to transport school children without violating Federal law, even though it may not comply with Federal school bus safety standards. That is because individual states have the authority to regulate the use of vehicles. Therefore, to ascertain whether one may use noncomplying vehicles to transport school children, one must look to state law. It is this agency's position that vehicles meeting Federal school bus safety standards are the safest way to transport school children.

Please find enclosed a pamphlet issued by this agency entitled Federal Motor Vehicle Safety Standards and Regulations, which summarizes our safety standards. Specifically, the following standards include requirements for school buses:

Standards 101 through 104;

Standards 105 (school buses with hydraulic brakes)

Standards 106 through 108; Standards 111 through 113;

Standard 115;

Standard 116 (school buses with hydraulic service brakes);

Standards 119 and 120;

Standard 121 (school buses with air brakes);

Standard 124;

Standard 131 (effective September 1, 1992);

Standards 201 through 204 (school buses with a gross vehicle weight rating (GVWR) of 10,000 pounds or less);

Standard 205;

Standards 207 through 210;

Standard 212 (school buses with GVWR of 10,000 pounds or less);

Standard 217;

Standard 219 (school buses with GVWR of 10,000 pounds or less);

Standard 220;

Standard 221 (school buses with GVWR greater than 10,000 pounds);

Standard 222;

Standards 301 and 302.

Some of the above-listed standards have unique requirements for school buses, including, but not necessarily limited to, Standards 105, 108, 111, 217, and 301. Other standards are applicable only to school buses, such as Standards 131, 220, 221, and 222. Standard 131 was promulgated on May 3, 1991 and may be found at 56 Federal Register 20370. It requires all school buses manufactured after September 1, 1992, to be equipped with stop signal arms. Standard 220 establishes requirements for school bus rollover protection. Standard 221 establishes strength requirements for school bus body panel joints. Standard 222 establishes minimum crash protection levels for occupants of school buses. Under the provisions of Standard 222, small school buses, that is those with a GVWR of 10,000 pounds or less, must be equipped with lap belts. For large school buses, those with a GVWR greater than 10,000 pounds, the standard requires occupant protection through "compartmentalization," a concept which calls for strong, well-padded, well-anchored, high-backed, evenly spaced seats.

Should you wish copies of our safety standards, I am enclosing for your information a fact sheet prepared by this office entitled Where to Obtain NHTSA's Safety Standards and Regulations.

I hope this information is helpful. If you have further questions in this regard, please feel free to contact Mr. Walter Myers of my staff at this address or by telephone at (202) 366-2992.