Interpretation ID: 77-3.23

TYPE: Interpretation-NHTSA

DATE: July 12, 1977

FROM: Joseph J. Levin, Jr. -- Chief Counsel, NHTSA

TO: Jim Thomason -- State Purchasing Office

TITLE: None

ATTACHMT: Attached to letter dated 9-10-90 from P.J. Rice to E. Kultgen (A36; VSA 108(b)(1); VSA 102(14); Part 571.3); Also attached to letter dated 5-29-90 from E. Kultgen from S.P. Wood (OCC 4843); Also attached to letter dated 5-10-82 from F. Berndt (signature by S.P. Wood) to M.V. Chauvin; Also attached to letter dated 3-27-78 from J.J. Levin, Jr. to B. Nanninga (VSA 102(14)); Also attached to letter dated 8-3-77 from J.J. Levin, Jr. to J.L. O'Connell (VSA 102(14))

TEXT:

Pursuant to your telephone conversation of June 9, 1977, with Roger Tilton of my staff, I am enclosing a copy of the National Highway Traffic Safety Administration's (NHTSA) interpretation that buses transporting people to and from college need not comply with the requirements of the new school bus safety standards.

You also asked whether buses used to transport people to and from vocational school would need to comply with the school bus safety standards. The applicability of the standards to vehicles purchased by an institution depends upon the nature of the particular institution. The school bus safety standards apply to vehicles purchased by "primary, preprimary and secondary schools." Since the vocational school you describe involves the training of adults and other post-high school students, it would not fall within the categories of primary, preprimary or secondary schools. Accordingly, buses used by that school would not need to comply with the school bus safety standards. However, vocational schools connected with secondary schools would fall within the ambit of the standards.