Interpretation ID: 2654o

Martin Chauvin
Chief, Carrier Safety Bureau
State of New York
Department of Transportation
Albany, NY 12232

Dear Mr. Chauvin:

This is a response to your letter of last year where you asked us to address a statement allegedly made by an unidentified school bus manufacturer that a school bus driver's seat equipped with an upper torso restraint or shoulder harness violates "head impact protection" requirements contained in the Federal Motor Vehicle Safety Standards. I apologize for the delay in this response. Nothing in our Federal standards prohibits a manufacturer from installing a seat belt assembly that includes a lap belt and upper torso restraint at the driver's seat of a school bus.

Standard 208, Occupant Crash Protection, specifies occupant protection requirements for the driver's seat of all buses. Section S4.4 of that standard gives a manufacturer the choice of equipping a bus driver's seat either with a complete automatic restraint system, a Type 1 seat belt assembly (which consists of a lap belt), or a Type 2 seat belt assembly (which consists of a lap and shoulder belt). There are no "head impact protection" requirements in Standard No. 208 for the driver's seating position in a bus. Thus, the driver's seat of all buses may be equipped with a lap and shoulder belt if the manufacturer chooses to do so.

Standard 222, School Bus Passenger Seating and Crash Protection, sets forth additional requirements for occupant crash protection for school buses. Section S5.3 of Standard 222 refers to a "head protection zone," and establishes head impact requirements within the head protection zones. However, the head protection zones are established with respect to passenger seats in the school bus. Standard 222 does not contain any head impact protection requirements for the driver's seat in school buses.

I hope you find this information helpful.

Sincerely,

Erika Z. Jones Chief Counsel ref:208#222 d:2/11/88