Interpretation ID: nht91-6.25

DATE: October 16, 1991

FROM: Floyd J. Barkman -- Vice President Sales & Marketing, Collins Bus Corporation

TO: Susan Schruth -- Office of Chief Counsel, U.M.T.A.

TITLE: None

ATTACHMT: Attached to letter dated 12-6-91 from Paul Jackson Rice to Floyd J. Barkman (A38; Std. 208)

TEXT:

We have been referred to your office to help us clarify recent laws involving commercial buses. We are manufacturer of both small and medium buses for both private customers and U.M.T.A. funded agencies. The following is a list of questions we would like your office to clarify:

1. Based on a final ruling that went into effect September 1, 1991, all MPV and/or buses with a gross vehicle weight less than 10,000 pounds are required to have Type 1 or Type 2 occupant restraints at all seated positions. Also, all outboard occupants or passengers are required to have three point shoulder harness. We also understand school buses are exempt from the outboard shoulder harness. Are these statements correct and are there any exceptions to these rulings?

2. We build under 10,000 GVW buses for the day care industry that use school bus safety seats and lap belts at all locations. The exterior of the bus is commercial. Would these buses require the outboard shoulder harness?

We would appreciate your earliest reply as we have new buses in production that will be effected by this law.