ID: nht87-2.8

TYPE: INTERPRETATION-NHTSA

DATE: 06/11/87

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Laurel Osborne -- Regional Coordinator, National Coalition for Seatbelts on School Buses

TITLE: FMVSS INTERPRETATION

TEXT:

Ms. Laurel Osborne Regional Coordinator National Coalition for Seatbelts on School Buses P.O. Box 225 Galena, Alaska 99741

Dear Ms. Osborne:

This responds to your January 29, 1987 letter to Mr. Barry Felrice, NHTSA Associate Administrator for Rulemaking, asking about our agency's position on safety belt use in small school buses (i.e., school buses with gross vehicle weight ratings (GVWR) of 10,000 pounds or less). Your letter has been referred to me for reply.

In your letter, you explain that you and the Alaska School Bus Safety Committee are interested in Alaska's implementation of Highway Safety Program Standard No. 17, Pupil Transportation Safety. You request clarification of NHTSA's position on safety belt use in small school buses because members of the committee believe that safety belts are provided on those buses only for the use of special education students. You also request information on safety belt education programs that schools could use to enc ourage the proper use of safety belts by student passengers in small school buses.

As you might know, NHTSA has two sets of regulations for school buses. The first set, issued under the authority of the National Traffic and Motor Vehicle Safety Act, applies to the manufacture and sale of new school buses and includes our motor vehicle safety standards for school buses. One of these safety standards is Federal Motor Vehicle Safety Standard No. 222, School Bun Passenger Seating and Crash Protection, which required the safety belts for passengers on small school buses. The second set of regulations, issued under the Highway Safety Act, includes Highway Safety Program Standard No. 17 and relates to the use of School vehicles. Because requirements for the use of school buses are set by the states, Standard No. 17 sets forth recommendation s to the station for the pupil transportation aspect of their highway safety programs. We encourage states to consider Standard No. 17's recommendations but do not insist on compliance with every aspect of the standard.

As you are aware, NHTSA does not believe that a Federal requirement for safety belts on large school buses (GVWR greater than 10,000 pounds) is necessary because large school buses are very safe vehicles due to their mass, seating configuration and "comp artmentalized" seating positions. However, because small school buses experience greater force levels in a crash, Passengers on these vehicles need the added safety benefits of the belts to mitigate against injuries and fatalities. Of course, the belts o n small school buses provide safety benefits only if they are properly used. We thus recommend they be used by all pupils whenever the children are transported. This recommendation is consistent with Program Standard No. 17, which states, "Passengers in Type II school vehicles equipped with lap belts shall be required to wear them whenever the vehicle is in motion." (IV.C.3.d(5).)

With regard to your question about belt education programs, NHTSA and the National PTA have put together a "Safety Belt A/V Resource Kit" and a "Children's Training Kit" as part of our 1986 safety belt awareness campaign. The kit contains materials geare d toward increasing safety belt use by children in passenger cars, and might be helpful in promoting belt usage in small school buses. I am sending you the resource kits by separate cover.

Further, some states have developed their own safety belt education program; for school children. The person in your state who might be able to provide you with more information on the programs available in Alaska is:

Ms. Romayne Kareen Pupil Transportation Officer Pouch F State Office Building Juneau, Alaska 99811 (907) 465-2890

Also, enclosed in this letter is a February 1986 NHTSA report entitled, "School Bus Safety Belts: Their Use, Carryover Effects and Administrative Issues." The report describes an exploratory study of the experiences of various school districts with safet y belt programs for school buses. You might find the discussion of administrative and educational components of bus belt programs helpful.

I hope this information is of assistance. Please contact us if you have further questions.

Sincerely, Erika Z. Jones Chief Counsel Enclosure

P.O. Box 225 Galena, Alaska January 20. 1987

Barry Felrice Associate Administrator for Rulemaking National Highway Traffic Safety Administration 400 Seventh Street S.W. Washington. D.C. 20590

Dear Mr. Felrice:

I have been trying to work with the Alaska School Bus Safety Committee in an effort to implement Standard 17 in the State of AlasKa. Members of this committee feel that seatbelts are provided on small school buses only for the use of special education st udents.

In one school district the belts are buckled under the seats when the buses ate used on regular routes. In another district students must buckle up only if they have been misbehaving. The contractor reports a high rate of belt vandalism in this district.

I would appreciate a clarification concerning NHTSA s position on seatbelt use in small school buses. I would also appreciate any suggestions on seatbelt education programs which could be used in schools to encourage the responsible use of belts by stude nts in their small buses. Thank you very much.

Sincerely yours. Laurel Osborne, Regional Coordinator National Coalition For Seatbelts on School Buses

ID: 18080.ztv

Mr. L. W. Camp
Director, Automotive Safety Office
Environmental and Safety Engineering
Ford Motor Company
330 Town Center Drive
Dearborn, MI 48128

Dear Mr. Camp:

This is in reply to your letter of May 28, 1998, asking that we concur in your conclusion that Ford's "Auto Low Beam" feature complies with Federal Motor Vehicle Safety Standard No. 108.

The feature is intended for a vehicle equipped with a two-headlamp system. If the upper beam of one of the headlamps fails, the feature activates the lower beam of that headlamp and notifies the driver.

You point out that paragraph S5.5.9 of Standard No. 108 requires that:

"[t]he wiring harness . . . of each headlamp assembly shall be designed so that only those light sources intended for meeting lower beam photometrics are energized when the beam selector switch is in the lower beam position, and that only those light sources intended for meeting upper beam photometrics are energized when the beam selector switch is in the upper beam position."

You are concerned that S5.5.9 might not allow Ford to manufacture vehicles with the "Auto Low Beam" because the feature would energize a lower beam light source when the beam selector switch is in the upper beam position.

When an upper beam fails, the headlamp system would not meet S5.5.9. It is only when this type of failure occurs that the Auto Low Beam feature activates the lower beam. However, we do not view S5.5.9 as applying to a failure condition.

A supplementary lighting feature such as the Auto Low Beam is subject to the prohibition of S5.1.3 that it not impair the effectiveness of lighting equipment required by the standard. Although there will be an imbalance of headlamp beams when the Auto Low Beam operates, we do not believe that the automatic operation of the lower beam will impair the effectiveness of the upper beam. The Auto Low Beam provides an alternative headlighting system that will function until the safety performance of the original headlamp system can be restored.

In summary, the Auto Low Beam system is permissible as original equipment under Standard No. 108.

If you have any questions, you may call Taylor Vinson of this Office (202-366-5263).

Sincerely,
Frank Seales, Jr.
Chief Counsel
d.7/15/98
ref:108

ID: 1984-1.49

TYPE: INTERPRETATION-NHTSA

DATE: 05/09/84

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: MMC Services

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your letter inquiring about the test specifications of Safety Standards 203 and 204 and the New Car Assessment Program. You specifically asked about the positioning of a tilting steering wheel for each of those tests. The answers to your questions are as follows.

Standard No. 203 incorporates by reference Society of Automotive Engineers Recommended Practice J944, December 1965. SAE J944 provides that a steering wheel is to be mounted at the angle specified by the manufacturer's "package drawing." Therefore, a tilting steering wheel would be placed at the nominal design position set by the manufacturer.

Standard No. 204 does not specify the positioning of a tilt wheel. In Standard No. 204 compliance testing, our Office of Vehicle Safety Compliance positions adjustable steering columns and wheels at the midpoint of the tilt and telescope adjustments. In the case of your particular tilting steering wheel, there is no midpoint. Thus, we would test the vehicle with the steering wheel in the position which is closest to the geometric center of the steering column. Based on the sketch enclosed in your letter, it appears that tilt positions 2 and 3 of your wheel are at an equal distance from the geometric center of the steering column. Therefore, your tilt tilt steering wheel should be capable of complying when tested in either of those positions.

The New Car Assessment Program does not use the Standard No. 208 test procedures, but instead uses its own set of test procedures. Those procedures specify that an adjustable steering wheel is to be positioned at the midpoint of its tilt adjustment. Since there is no midpoint for your wheel, the wheel would be set at the position closest to the gometric center of the steering column. As discussed above, the agency would use either position 2 or 3 for your tilt wheel.

If you have any further questions, please let me know.

SINCERELY,

MMC SERVICES INC.

February 10, 1984

Frank Berndt Chief Counsel National Highway Traffic Safety Administration U.S. Department of Transportation

Subject: Test Conditions of FMVSS 203, 204 and NCAP Dear Sir:

This is to inquire about the test specifications of FMVSS 203, 204 and NCAP (New Car Assessment Program) regarding tilt steering.

1. Our interpretations are as follows:

(1) FMVSS 203 (SAE J944)

The height of the steering wheel shall be adjusted to the manufacturer's design reference point.

(2) FMVSS 204

No description of the adjusting method for the tilt steering.

(3) NCAP

The NCAP's test is conducted according to FMVSS 208; S8.1.4 which states "Adjustable steering controls are adjusted so that the steering wheel hub is at the geometric center of the locus it describes when it is moved through its full range of driving positions.

2. Tilt Steering Mechanism

Our tilt steering for the future model is only adjusted at four (4) positions by the gear, and therefore, the steering wheel hub is not set at the geometric center of the locus as required in FMVSS 208. (See the figure on the following page)

(Graphics omitted)

3. Questions

(1) Are our interpretations as mentioned above correct? If not, please let us know of your interpretations.

(2) When performing the 35 mph frontal collision test, at which gear position do we set the steering wheel hub?

(3) At which gear position shall we set the steering wheel hub for the following respective tests?

(a) FMVSS 203

(b) FMVSS 204

Masakatsu Kano Executive Vice President

MMC SERVICES, INC.

ID: 1982-1.5

TYPE: INTERPRETATION-NHTSA

DATE: 01/13/82

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Blue Bird Body Company

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your letter of October 26, 1981, requesting several interpretations of the requirements of Standard No. 201, Occupant Protection in Interior Impact. The answer to each of your questions is discussed below.

Your first question concerned section 3.3 of the standard, which among other things, requires that an "interior compartment door assembly located in . . . a side panel adjacent to a designated seating position . . ." must remain closed when tested under certain conditions. You stated your belief that the requirement only applies to interior compartment doors located within the head impact area, defined in Part 571.3 of Title 49. You asked if the area adjacent to a designated seating position is to be determined by projecting laterally from the head impact area for a designated seating position to the side panel next to it.

The impact protection requirement for interior compartment doors was added to the standard on October 25, 1968 (33 FR 15794). As explained in that notice, a copy of which is enclosed, the agency specifically denied requests to limit the interior compartment door requirement to doors located in the head impact area. The requirement is designed to provide protection to the head and other portions of an occupant's body that can be thrown against an interior compartment door opened by inertial forces in a crash. To accomplish the purpose of the standard, any interior compartment door, defined in Part 571.3 of Title 49, that is located in a side panel and is next to a designated seating position is covered by the requirements of section 3.3 of the standard.

You also asked how the term "instrument panel" is defined for the purposes of section 3.3 of the standard. You are correct that the term refers to the panel below the windshield which is used to mount the speedometer, other gauges, etc. For the reasons discussed in response to your first question concerning S3.3, any interior compartment door on the instrument panel is covered by the requirements of section 3.3, not just those located in the head impact area.

You also asked about the requirements of section 3.3.1 of the standard. You state that section 3.3.1 allows the use of either option (b) or (c) to show compliance. Your statement is not correct. Section 3.3 of the standard requires more than compliance with either option (b) or (c) of section 3.3.1. Section 3.3 requires interior compartment doors to remain closed when "tested in accordance with either S3.3.1(a) and S3.3.1(b) or S3.3.1(a) and S3.3.1(c)."

You also state that you interpret option (c) of section 3.3.1 to be a horizontal inertial load of 30g in a longitudinal direction which would simulate a forward 30 mile per hour flat barrier impact. Your interpretation is correct. Section 3.3.1(c) provides that an interior compartment door latch must be subject to "a horizontal inertia load of 30g in a longitudinal direction in accordance with the procedures described in section 5 of SAE Recommended Practice J839b, 'Passenger Car Side Door Latch Systems,' or an approved equivalent." The purpose of the requirement is to impose loads similar to the loads experienced by a door latch tested in the 30 mile per hour forward barrier crash required by section 3.3.1(b) of the standard.

You further state that the loading applied in accordance with section 3.3.1(c) should be a forward deceleration inertia loading. Your interpretation is not correct. To ensure that the requirements of sections 3.3.1(b) and 3.3.1(c) are equivalent in stringency, the agency believes that the 30g inertia load requirement of section 3.3.1(c) must take into account the distortion and deformation that would occur in a 30 mile per hour barrier impact. Therefore, the 30g inertia load must be applied in both the forward and rearward direction. Likewise, the 10g inertia load requirement of section 3.3.1(a) must be applied in both the inboard and outboard direction.

Your final question concerned the requirements of section 3.5.1 of the standard, which specifies that armrests must comply with at least one of three options. Section 3.5.1(c) specifies that one option is providing an armrest which has "Along not less than 2 continuous inches of its length . . . when measured vertically in side elevation. . . at least 2 inches of coverage within the pelvic impact area." You are correct that an armrest complying with section S3.5.1(c) can be made of any material, as long as it meets the dimensional requirements set by that section.

If you have further questions, please let me know.

ENC.

BLUE BIRD

BODY COMPANY

October 26, 1981

Frank Berndt Chief Counsel National Highway Traffic Safety Administration Department of Transportation

Reference: FMVSS 201 Occupant Protection in Interior Impact Passenger Car

FMVSS 201, Section 3.3, Interior Compartment Door, states, "a compartment door located in . . . side panel adjacent to a designated seating position . . . ". Blue Bird Body Company interprets this phrase to be an area projected laterally to the side panel from the Head Impact Area as defined by Part 571 Subpart A - Definitions.

This interpretation is based on the concept that FMVSS 201, Section 3.3 is intended to prevent occupant head contact with an inertia opened compartment door during a crash. The Head Impact Area defines the trajectory of the occupant head during such a crash, and thus would define the area of potential head to compartment door contact. Compartment doors within this projected area should comply with Section 3.3, while those outside of this area should be exempt. This is also consistent with the American Heritage Dictory definition of adjacent as being next to; or adjoining. This definition would exempt panels located above the door or upper window header.

Blue Bird Body Company also defined "instrument panel" as referenced in Section 3.3, to be the panel below the windshield that normally is used to mount gages, speedometers, etc, to monitor vehicle functions and that is within the Head Impact Area as defined in Subpart A - Definitions.

Section 3.3.1, Demonstration Procedures, allows either option (b) or (c) to show compliance. Blue Bird Body Company interprets option (c) to a horizontal inertia load of 30g in a longitudinal direction which would simulate a forward 30 miles per hour flat barrier impact, as required by option (b). This would be a forward deceleration inertia loading applied in accordance to Section 5 of the SAE Recommended Practice J839b.

Under Armrest, Section 3.5.1, General, option (c) specifies "not less than two continuous inches of its length, the armrest shall, when measured vertically in side elevation, provide at least 2 inches of coverage within the pelvic impact area". Blue Bird Body Company interprets this to allow any material, including steel tube, aluminum or steel panel, that fulfills the dimensional requirements.

We respectfully request your confirmation of our interpretation to the above sections of FMVSS 201. An early reply would be apprediated.

Thank you.

Thomas D. Turner Manager Engineering Services

ID: nht68-1.28

DATE: 01/01/68 EST.

FROM: H.M. Jacklin, Jr.; NHTSA

TO: Electrical Testing Laboratories, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letters of July 30, and August 9, 1968, concerning the test of seat belt anchorages which are anchored to a seat.

On the question regarding the test method for applying the loads specified in paragraph $3.1.1, Motor Vehicle Safety Standard No. 207, we would agree with your conclusion to apply the loads at the required different points and directions simultaneously.

On the question of whether bucket seats with seat belt anchorages attached may be tested separately, the applicable paragraph in SAE J787b is 5.2 rather than 5.1 as stated in your letter. There is no test method specified therein relative to this question and accordingly, test of the bucket seat with seat belt anchorages attached may be tested either separately or in sets.

ID: 7822

Jess R. Thurman
13112 Old State Road
Evansville, IN 47711

Dear Mr. Thurman:

This responds to your letter of October 1, 1992 requesting information on whether certain modifications can be made to a van to make room for a wheelchair to enter the vehicle. You explained that you currently own a 1983 Ford van with a lift. The passenger seats behind the front seats were moved back in your 1983 van to make room for the wheelchair lift. You are currently trying to purchase a new Ford van with the same modifications but have been told that federal law no longer permits moving seats or safety belts. As explained below, there is no federal requirement that expressly prohibits moving seats or safety belts, provided that the relocated seats and belts continue to comply with the applicable safety standards.

Section 103 of the National Traffic and Motor Vehicle Safety Act (the Safety Act; 15 U.S.C. 1392) authorizes NHTSA to issue Federal Motor Vehicle Safety Standards for new motor vehicles and new items of motor vehicle equipment. Manufacturers are required to certify that their products meet all applicable safety standards. Thus, if a vehicle were originally manufactured in the manner you have described, the manufacturer would be required to certify that the vehicle complies with all applicable safety standards. If some party were to modify a vehicle along the lines described in your letter before the vehicle's first sale to a consumer like yourself, that party would be required to leave the original manufacturer's certification in place and add its own certification that the vehicle as altered continues to comply with all applicable safety standards.

Moving the rear seats and the seat belts for those seats could affect compliance with four safety standards: Standard No. 207, Seating Systems, Standard No. 208, Occupant Crash Protection, Standard No. 209, Seat Belt Assemblies, and Standard No. 210, Seat Belt Assembly Anchorages. Standard No. 207 establishes strength and other performance requirements for vehicle seats. Standard No. 208 sets forth requirements for occupant protection at the various seating positions in vehicles. Based upon the information in your letter, it appears that the vehicle you wish to have modified would be classified as a multipurpose passenger vehicle (MPV) for purposes of NHTSA's regulations. Standard No. 208 requires an MPV to have a lap/shoulder belt at every rear outboard seating position, and either a lap belt or a lap/shoulder belt at every other rear seating position. Standard No. 209 sets forth strength, elongation, webbing width, durability, and other requirements for seat belt assemblies. Standard No. 210 establishes strength and location requirements for seat belt anchorages.

Any manufacturer, distributor, dealer, or repair business that modifies a van for you along the lines described in your letter after you have purchased the van would be subject to the requirement of the Safety Act (at 15 U.S.C. 1397(a)(2)(A)) that:

No manufacturer, distributor, dealer, or motor vehicle repair business shall knowingly render inoperative, in whole or in part, any device or element of design installed on or in a motor vehicle . . . in compliance with an applicable Federal motor vehicle safety standard.

Since the rear seats and their safety belts are devices or elements of design installed in the van in compliance with applicable safety standards, this section prohibits any of the named commercial entities from making any modification or repair to the rear seats and/or their accompanying safety belts if such modification or repair would cause the vehicle no longer to comply with an applicable safety standard.

As you can see, there is nothing in Federal law that prohibits persons from moving rear seats and their accompanying safety belts. Instead, Federal law requires that modifications to a van that include moving the rear seats and the safety belts be done in such a way that the repositioned seats and safety belts continue to provide the safety protection mandated by the safety standards.

I hope you find this information helpful. If you have any other questions or need some additional information on this matter, please contact Mary Versailles of my staff at this address or by phone at (202) 366-2992.

Sincerely,

Paul Jackson Rice Chief Counsel ref:207#208#209#210 NCC-20:MVersailles:amb:62992:10/22/92 U:\NCC20\INTERP\208\7822.MLV cc: NCC-01 Subj/Chron, NCC-20 MV, NRM-01, NEF-01 Interps: 207, 208, 209, 210, Redbook (8)

ID: aiam0342

Dear Mr. Nakajima:#This is in reply to your letter of April 1 seeking clarification of paragraph S4.1.2 of Motor Vehicle Safety Standard No. 104.#We confirm your understanding that S4.1.2 excludes any part of wiped areas A, B, and C that lie outside the perimeter line. Change of your driver's seating reference point to meet the proposed requirements of Standard No. 201 does not affect the percentage of area A, assuming no change in the perimeter line.#Sincerely, Lawrence R. Schneider, Acting Chief Counsel;

ID: nht91-1.9

DATE: January 3, 1991

FROM: Jim Holperin -- State Representative, 34th Assembly District

TO: Taylor Vinson -- Legal Counsel, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 2-26-91 from Paul Jackson Rice to Jim Holperin (A37; Std. 108)

TEXT:

I write today on behalf of LeRoy E. Mueller, President of the Wisconsin Trailer Company, Inc. in Phelps, Wisconsin. Mr. Mueller's company recently submitted a bid to the Wisconsin Department of Natural Resources for two tilt-deck trailers based on the enclosed specifications.

As Mr. Mueller is concerned that if he builds the trailers exactly to specifications that they will be in violation of Title 49, Section 571-108 and, by cross reference, in violation of relevant SAE requirements.

Kevin Cavey recommended I direct this correspondence to you and request a determination from the NHTSA regarding whether our DNR's trailer specifications comply with Title 49 and relevant SAE codes. I am also enclosing a letter from Mr. Mueller indicating his primary concern lies with what appears from the specifications to be a permanent, stationary ramp which Mr. Mueller believes might obscure a clear view of the trailer's tail lights from a 45 degree angle as required by Title 49 and SAE codes.

I would appreciate it if you could take time to review the enclosed material and determine whether Mr. Mueller's concerns regarding an obstructed view of the tail light are legitimate or not. Thank you for giving this request your consideration and, of course, if there is additional information you need please do not hesitate to contact me by letter or phone.

Attached to a map of the 34th Assembly District (Text omitted)

Attachment Specification 8 SPECIFICATION

TYPE: (2) Two 26,000 lb. minimum payload capacity "over the wheel" tilting platform trailer.

DELIVERY: The successful bidder shall deliver all units ordered, after final inspection and approval by DNR personnel, to DNR, Neil H. LeMay Forestry Center, 518 West Somo Ave., Tomahawk, WI 54487, and to arrive during regular working hours - Monday thru Friday, 7:45 a.m. to 11:45 a.m. and 12:30 p.m. to 4:30 p.m. Advance notice of at least one day shall be given. The successful bidder shall arrange for and pay transportation costs for the delivery of all units ordered.

USE: Trailer will be used to transport medium sized crawler tractors with fire plows, heavy duty wheel tractors, and farm-type machinery, both on and off the road, maximum highway speed will be 55 MPH.

A. CAPACITY: 26,000 lb. minimum payload capacity. When unloaded, there shall be sufficient tongue weight to enable the unit to be towed without fish-tailing.

OUTLINE DRAWING - T-D169-401 Issue 02

B. PLATFORM: Length - 20 feet Width - 94" minimum - 96" maximum Height - 38" maximum fully loaded

FRAME: Steel shall be designed with ample safety factor and electrically welded where steel meets steel. All crossmembers are to be in line, fully welded on top, sides, and bottom, both on the inside and outside of the main frame.

DECK: Full 2 inch thick treated apitong wood deck. The entire rear 7 feet of the trailer to be ribbed traction bed with 3.75" x 2" x 3" angle steel ribs replacing the wood deck planking. Ribs to be spaced 7" on center with the 3" leg facing the front of the trailer. All wheel well openings shall be covered. Area around wheel wells shall be reinforced to support deck.

ANGLE IRON LOADING GUIDES: Locate three removable angle iron guides on top of deck per outline drawing.

Stake pockets, footholds, expanded metal walkway, tie-down slots per outline drawing.

LOADING RAMPS: 0.50" thick steel formed loading ramps per outline drawing.

PLATFORM LOCK: Shall be heavy duty screw type, self adjusting for wear, and shall hold the platform tight and rattle free in the closed position, The end of the screw shall be wedge shaped for ease of engagement.

OPERATION: Deck to tilt open or closed with 150 lb. weight, allowing loading or unloading of equipment. Loading angle shall not exceed 15 degree incline. Zerk type grease fittings shall be on all platform tilt pivot points.

SPECIFICATION

CUSHIONING DEVICE: One (1) 4" hydraulic cylinder with 1.25" diameter rod, or two (2) 2.5" hydraulic cylinders with 1" diameter rod (all minimum dimensions) designed to cushion the opening and closing the platform. When cylinders are completely open, the bed of trailer shall be capable of tilting 4" minimum below ground level in the tiltbed position.

C. SUSPENSION: Single point spring suspension - Neway USR 444, or equal - able to maintain equal ground pressure while traveling over uneven terrain.

AXLE LOCATION: Distance from center of axles to front of trailer bed to be approximately 10 feet.

TIRES: Nine (9) 7.5 x 15 L.R. "F" (12PR) low platform trailer tube type tires and rims capable of meeting load and speed requirements of this specification as noted in item A. One (1) tire to be mounted on spare rim. Valve extensions required on inside tires.

WHEEL: Budd disc wheels. Stemco oil wheel seals shall be furnished on all axles.

AXLES: Full width through type axles with one (1) hubometer.

D. BRAKES: Full air complete with all lines, breakaway control valve, and air reservoir tank with 1,000 cubic inch minimum capacity. Air brake hoses to extend a minimum of 24" ahead of the pintle eye and shall be complete with couplings. Air lines shall not be interchangeable. Left gladhand shall be the emergency air line Velvac #55B-13. Right hand gladhand shall be the service air line Velvac #55B-14. Brake system shall meet SAE and DOT requirements. All wheel brakes to be 12.25" x 7.5" minimum. Gladhand holders are required for brake lines when they are not in use, and are to be mounted near tongue. Include piggy back parking with mechanical release and mechanical release tool.

E. ELECTRICAL SYSTEM: Shall be per writing diagram T-AO86-701 furnished as a part of this specification.

WIRING: Shall meet all SAE, ICC, and DOT requirements. All wires shall be in loom, heavy jacket, or conduit and mounted in a protected position. Where wires pass through steel, they shall be protected with rubber grommets. Two (2) feet of conductor wire, ahead of pintle, shall be installed in the female plug for connection to the towing vehicle. No aluminum rivets for grounds are allowed.

LIGHTS: Lights shall meet SAE, ICC, and DOT requirements. Lights shall be in protected recesses or with protective base around lights. All lights shall be of the plug-in type.

SIX POLE PLUG: Vel Vac #59P-6 (6 way male plug) with replaceable interior, or equal.

Attached to drawings and photos of Lid Trailer (Text and graphics omitted)

ID: nht79-2.9

DATE: 05/21/79

FROM: AUTHOR UNAVAILABLE; S. P. Wood for F. Berndt; NHTSA

TO: Blue Bird Body Company

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your March 13, 1979, letter in which you ask whether a seat that does not have another seat immediately behind it must comply with the rearward performance requirements of Standard No. 222, School Bus Passenger Seating and Crash Protection. The seat to which you refer is abutted by a portion of a lift device for handicapped students. Behind the lift structure, itself, is a restraining barrier and more seats.

Standard No. 222 states that any seat that has another seat behind it must comply with the rearward performance requirements. The effect of this statement is to exclude rear seats from complying with the rearward performance requirements. In the Federal Register notice of April 23, 1975, the agency stated that it was adopting this approach to save costs in school buses without impairing the safety of those vehicles. The agency indicated that the passengers in the rear seat were protected as well as passengers in other seats, because they can "ride down" the vehicle structure rather than the seat back in an accident (40 FR 17855).

The above analysis is equally appropriate for other seats that are directly in front of some substantial vehicle structure. The lift mechanism depicted in your picture and diagram appears to offer similar "ride down" benefits to passengers as does the rear wall structure of a vehicle. Accordingly, the agency considers the rearward performance requirements to apply in situations such as yours only when a seat is immediately in front of another passenger seat. The agency cautions, however, that this interpretation applies only in those instances where the affected seat is in front of some substantial vehicle structure. If the seat does not have the benefit of vehicle structure behind it, it must comply with the rearward performance requirements.

SINCERELY,

BLUE BIRD BODY COMPANY

March 13, 1979

Roger Tilton Office of Chief Counsel National Highway Traffic Safety Administration

SUBJECT: FMVSS 222 PARAGRAPH S5.1.4 SEAT PERFORMANCE REARWARD

REFERENCE: Telephone conversation between W. G. Milby and Roger Tilton March 6, 1979.

Dear Mr. Tilton:

The subject paragraph says "when a school bus passenger seat that has another seat behind it is subjected to the applications of force . . .". The effect of this language is to not require the rear most seats in a school bus to be subject to the rearward performance requirements of FMVSS 222.

The rationale behind this is that the rear structure of the bus body will restrict the seat back from excessive rearward deflection. The purpose of this letter is to seek a similar interpretation for seats which have other structures behind them (such as handicapped passenger lifts as described in the attached photo) which would insure that the rearward deflection does not exceed 8 inches as described in S5.1.4(b). An interpretation is necessary since in some floor plans, such as the ones described on the enclosed form number OE-79122 page 12, it is necessary to have some seating positions rearward of the lift. When this is the case, a barrier is placed between the rear portion of the lift and the next seating position, as shown on the enclosed floor plans. Although these seats are "behind" another school bus passenger seat, they are not immediately behind another seat which is the sense in which the language of S5.1.4 is used.

We thank you for your consideration in this matter and look forward to your early response.

W. G. Milby Manager, Engineering Services

(Graphics omitted)

SCHOOL BUS

ALL AMERICAN BLUE BIRD'S HANDY BUS 35" LIFT

SUGGESTED SEAT PLANS BODY MODEL AAFC3101 Body Sections Front to Rear: 179" W.B. Floor Plan Number: 0917484 5-28, 2-35, 4-28 Seat Plan Number: 0896696

BODY MODEL AAFC3101 Body Sections Front to Rear: 179" W.B. Floor Plan Number: 0914069(1) 3-28, 2-35, 6-28 Seat Plan Number: 0914325

(Graphics omitted)

(1) NOTE: Option 4594 Relocate 60 gal. fuel tank w/barrier must be ordered. Body Sections Front to Rear: 149" W.B. Floor Plan Number: 0850875 5-28, 3-35, 1-28 Seat Plan Number: 0914309

BODY MODEL AAFC2700 Body Sections Front to Rear: Floor Plan Number: 0850875 5-28, 3-35, 1-28 149" W.B. Seat Plan Number: 0850867

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ID: aiam3964

Dear Mr. Locker: This responds to your recent letter to Steve Kratzke of my staff seeking an interpretation of the requirements of Standard No. 213, *Child Restraint Systems* (49 CFR S571.213). Specifically, you asked if a belt which is attached to and is not easily removed from a movable shield is an integral part of the shield within the meaning of section S6.1.2.3.1(c), and may therefore be attached when the restraint is tested in test configuration II of Standard No. 213. Such a belt is an integral part of the movable shield and may be attached during test configuration II.; Your client, Collier- Keyworth, has designed a child restraint tha integrates the webbing of the upper torso restraint with the crotch strap and the movable shield in a continuous connection, with the bottom of the crotch strap webbing intended to be buckled to the base of the seat between the child's legs after the child is positioned in the restraint. As described in your letter and shown in the photographs enclosed therewith, the crotch strap portion of the webbing is considered an integral part of the movable shield, because it is formed as a unit with that shield. Hence, section S6.1.2.3.1(c) of Standard No. 213 allows you to attach the crotch strap portion of the webbing to the base of the seat during configuration II testing.; I suggest, however, that Collier- Keyworth incorporate into th restraint some means of alerting parents each time they place a child in the restraint that the crotch strap must be buckled into the base of the seat. This suggestion is based on past experience with child restraints which have both a movable shield and a crotch strap which must be buckled to adequately protect the child.; In the late 1970's, there were several child restraint designs whic had a crotch strap permanently attached to the base of the seat and a movable shield which lowered in front of the child. The designers of these restraints intended that the crotch strap be attached to the shield to properly restrain the child. However, such restraints were often misused by consumers who did not attach the crotch strap to the shield. NHTSA was concerned that in the event of a crash, a child occupant would submarine partly or completely out of restraints whose crotch straps were not fastened to the shield.; When amended Standard No. 213 was being promulgated, the agency decide to include some procedure for testing those child restraints whose design could lead a parent to believe that a child was adequately protected when the restraint was, in fact, being misused. In the case of restraints with movable shields, the agency believed that some parents would conclude that a child was protected by the restraint simply by lowering the movable shield in front of the child without buckling the crotch strap. Test configuration II in Standard No. 213 was intended to address this situation, by attempting to ensure that child restraint designs which would likely be misused would afford some minimal level of protection when they were misused. To achieve this end, test configuration II requires that child restraints with a movable shield in front of the child be tested in a 20 mile per hour crash with the shield in front of the test dummy, but without attaching any belts which are not an integral part of the shield.; Many previous interpretations of this standard explained that sectio S6.1.2.3.1(c) allows belts which are an integral part of the movable shield to be attached during configuration II testing because the agency believed that the need to buckle such belts would be more readily apparent than in the case of nonintegral belts. That is, a parent would be less likely to conclude that the child was adequately protected if the integral belt was not buckled.; During 1980, the manufacturers of the restraints with movable shield to which crotch straps were to be attached asked NHTSA if the crotch straps could be attached to the shield during configuration II testing if the movable shield were spring-loaded so that it would not stay in front of the child unless the crotch strap were attached. The agency concluded that the rationale for not allowing the nonintegral crotch strap to be fastened during configuration II testing would not apply if the crotch strap were to be fastened to spring-loaded movable shields. Unless these crotch straps were attached, there would be nothing in front of the child to restrain him or her in the event of a crash. Therefore, NHTSA decided it was unlikely that a parent would conclude that a child would be adequately protected without attaching these crotch straps, and permitted spring-loaded movable shields to attach nonintegral crotch straps during configuration II testing under Standard No. 213.; The shield on the Collier-Keyworth child restraint is not spring-loade and thus would remain in front of an occupant regardless of whether the crotch strap is fastened. Our examination of the photographs and materials enclosed with your letter suggests that it is possible a parent might conclude that a child was adequately protected simply by lowering the shield in front of the child without buckling the crotch strap. For instance, Figure 5 of Exhibit B shows the shield lowered and staying in place without buckling the crotch strap. I am sure that Collier-Keyworth wants to minimize the chances of this sort of misuse occurring, and will want to incorporate some means of alerting parents each time they place a child in the restraint that the crotch strap must be buckled. Such a means could be spring-loading the movable shield, sas would be required if the crotch strap were not an integral part of the shield, or could be a 'warning' label on the front of the shield explaining the need to buckle the crotch strap.; If you have any further questions or need more information on thi subject, please contact Mr. Kratzke at this address or by telephone at (202) 426-2992.; Sincerely, Jeffrey R. Miller, Chief Counsel