Interpretation ID: aiam4190
Specification Engineer
Thomas Built Buses
L.P.
P.O. Box 2450
High Point
NC 27261;
Dear Mr. Marion: This responds to your May 21, 1986 letter requesting an interpretatio of Federal Motor Vehicle Safety Standard No. 222, *School Bus Passenger Seating and Crash Protection*, as it applies to safety belts on large school buses. You asked first whether it is acceptable to install two safety belts on a 39-inch bench seat. Your second question asked whether such a seat would be designated as a two- or three- passenger seat.; In response to your first question, Standard No. 222 currently does no prohibit you from providing two safety belts on a 39-inch bench seat. This is because NHTSA does not require or set specifications for safety belts installed for passengers on large school buses, but for the requirement that the installation method not interfere with vehicles' compliance with applicable motor vehicle safety standards. However, the agency is currently considering an amendment to Standard No. 222 which would affect the voluntary installation of safety belts on 39-inch bench seats. If we adopt changes to the standard proposed in a notice published on October 10, 1985, safety belts voluntarily installed on large school buses must meet requirements similar to those established for safety belts on small school buses. Under the proposed requirements, manufacturers voluntarily installing safety belts would have to install three safety belts on a 39-inch seat. We are currently evaluating comments received on the proposal, and final action is anticipated in the near future.; In response to your second question, since your current option t install voluntarily two safety belts on a 39-inch bench seat does not affect your responsibility under the National Traffic and Motor Vehicle Safety Act to manufacture school buses which comply with all applicable requirements of Standard No. 222, the 39-inch bench seat to which you refer must be designated as a 3-passenger seat under S4.1 of the standard. You as a manufacturer must ensure that the seat meets the forward and rearward performance requirements, and other applicable requirements of Standard No. 222, based on calculations of *three* seating positions and the requisite force applications. While your bench seat might be occupied by fewer persons due to the safety belts, that calculation helps to assure that the seat provides adequate protection when occupied by the maximum number.; We note further that since under S4.1 a 39-inch bench seat i considered to have three designated seating positions, manufactures must not provide more than three safety belts on a 39-inch bench seat or otherwise imply that the seat is capable of carrying more than three passengers.; If you have any further questions, please let us know. Sincerely, Erika Z. Jones, Chief Counsel