Interpretation ID: nht88-3.3

TYPE: INTERPRETATION-NHTSA

DATE: 08/11/88

FROM: JOSEPH F. MIKOLL -- VICE PRESIDENT TRANSPORTATION EQUIPMENT CORP

TO: ERICA JONES -- CHIEF COUNSEL NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 03/10/89 FROM ERIKA Z. JONES -- NHTSA TO JOSEPH F. MIKOLL, REDBOOK A33, STANDARD 217, 222 AND 302; LETTER DATED 11/15/88 FROM JOSEPH F. MIKOLL TO ERIKA Z. JONES -- NHTSA; OCC 2812; LETTER DATED 11/03/88 FROM ERIKA Z. JO NES -- NHTSA TO JOSEPH F. MIKOLL

TEXT: Dear Ms. Jones:

We are writing to you to confirm our understanding that our "Impact Control System", or safety bar is not in conflict with any existing standard for installation in school buses. The device was presented to various staff peopled in NHTSA on July 28, 1988. Our principal contact was Dr. Carl Clark.

Transportation Equipment Corp. was formed in December 1987. The company has conducted extensive market research to determine the concerns of the numerous interest groups who would be affected by installation of our system. The engineering and design process undertaken has resulted in solving two major problems involving the safe transportation of school bus passengers; 1) a drastic reduction of HIC (Head Injury Criteria) numbers by spreading the load across the chest, and 2) overcoming the utility problems associated with seat belt use on school buses.

Included for your review and evaluation are the following materials:

Engineers drawings and photographs of the device.

Video tape and written documentation of the dynamic testing conducted at the University of Michigan Transportation Research Institute.

Independent Consultants opinion on the design and dynamic test results.

Background information on our Consulting Engineers.

We have identified those vehicles under 10,000 pounds (small buses & mini vans) as a target market for installation of our system. At present, these vehicles are under a federal mandate to be equipped with seat belts. It is our objective to have our device offered as an alternative option to seat belts in this class of vehicle. We respectfully request your opinion concerning a ruling and/or confirmation of the systems acceptance as an alternative option.

If we have omitted any information needed to consider this matter, please do not hesitate to contact us.

We look forward to hearing from you at your earliest convenience.