Interpretation ID: 18049.drn

Ms. Angela Asher
Paralegal
Jablinski, Folino, Roberts, & Martin
P.O. Box 1266
Dayton, OH 45402-9766

Dear Ms. Asher:

As you requested, enclosed is a copy of a May 10, 1982 interpretation letter from Frank Berndt, then National Highway Traffic Safety Administration (NHTSA) Chief Counsel, to Mr. Martin V. Chauvin. The letter discusses whether vehicles used to transport children to or from day care centers and summer camps must meet school bus safety standards. There is no charge for the letter.

Please note that the Chauvin letter's issue does not address situations where the day care center or summer camp is picking up or dropping off students at school. I am enclosing a June 1, 1998, letter discussing a dealer's responsibility in leasing new buses to a dance studio that will pick up the children from school "five days a week." In the June 1998 letter, NHTSA explains that the dealer must lease only buses that meet Federal motor vehicle safety standards for school buses.

If you wish guidance on a specific situation involving dealers' responsibilities on sales of vehicles to transport school children, I will be glad to provide an interpretation.

I hope this information is helpful. If you have any further questions, please contact Dorothy Nakama of my staff at this address or at (202) 366-2992.

Sincerely,
Frank Seales, Jr.
Chief Counsel
Enclosures
ref:VSA#571.3
d.8/28/98