Interpretation ID: nht87-2.26

TYPE: INTERPRETATION-NHTSA

DATE: JUNE 29, 1987

FROM: MARTIN V. CHAUVIN -- CHIEF CARRIER SAFETY BUREAU, STATE OF NEW YORK

TO: ERIKA Z. JONES -- CHIEF COUNSEL, NHTSA

TITLE: NONE

ATTACHMT: MEMO DATED 2-11-88, FROM ERIKA Z. JONES - NHTSA, TO MARTIN CHAUVIN

TEXT: The New York State Department of Transportation is reviewing a proposal to add a requirement for the driver's seat on school buses.

The proposal being reviewed recommends that all driver's seats on school buses be equipped with a pelvic and upper torso restraint or what is referred to as a "Type 2 Seat Belt Assembly." One of the school bus manufacturing companies has indicated that t he upper torso restraint or shoulder harness cannot be provided as it would violate the requirements for head impact protection as contained in the Federal Motor Vehicle Safety Standards. As part of our overall review, we ask that this statement be addr essed by your agency.

In reports issued by organizations such as the National Transportation Safety Board, it is indicated that the Type 2 Seat Belt Assembly is far superior to the Type 1 Seat Belt Assembly in passenger car use. It is reasonable to make the assumption that t his superiority would apply equally well to school bus driver seats as well. In considering the vital role the school bus driver is expected to play in the event of an accident, it is extremely important that we provide the best protection available.

We are currently in the process of developing the legislative proposals to amend our laws and would greatly appreciate a timely response to this request. If there is any need to further discuss this request, the undersigned can be reached at (518) 457-1 010.

Thank you.