ID: nht78-1.16

DATE: 02/14/78

FROM: AUTHOR UNAVAILABLE; J. J. Levin, Jr.; NHTSA

TO: M. H. Hollaway

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your September 16, 1977, letter asking whether it is illegal to mount a tire labeled "Farm Tire" on a passenger car.

Tires manufactured for use on passenger cars or other motor vehicles designed principally for highway use must comply with all Federal regulations applicable to those tires. Tires designed for use on farm vehicles, on the other hand, are not required to comply with the Federal motor vehicle safety standards.

Under section 108 of the National Traffic and Motor Vehicle Safety Act (Pub. L. 89-563) a dealer may not "knowingly render inoperative" a device installed on a motor vehicle in compliance with a safety standard. A dealer who removes properly certified passenger car tires from an automobile and replaces them with tires that are specified for farm use would be in violation of section 108 in that the complying tires would have essentially been rendered inoperative by his actions. Section 108 does not apply to private individuals. Thus, a car owner would not be in violation of the law if he accomplished the tire replacement himself. Such action would be highly inadvisable, however, since these restricted use tires are not constructed in compliance with standards that ensure a minimum safe level of performance for highway operation.

Sincerely,

ATTACH.

September 16, 1977

Department of Transportation Washington, D. C. 20013

Gentlemen;

Will you please answer the following question?

Is it unlawful to use tires on a passenger car that are marked "Farm tires"?

These tires are passenger car type tires with white sidewalls. However, a local tire store refused to install them because of the markings.

Thank you for your assistance.

Yours Truly,

M. H. Hollaway

MARCH 7, 1978

M. H. Holloway

Dear Mr. Holloway:

This is in further reply to your September 16, 1977, letter asking whether it is illegal to mount a tire labeled "Farm Tire" on a passenger car.

We inadvertently neglected to point out in our February 14, 1978, response to your letter that any tire which is marked with a Department of Transportation (DOT) symbol is presumed to meet all Federal Motor Vehicle Safety Standards that apply to it. Any tire with such a symbol may therefore be mounted on a motor vehicle without violation of Section 108 (a)(2)(A) of the National Traffic and Motor Vehicle Safety Act when the former tires are removed, regardless of the appearance of words associating the tire with farm use.

Sincerely,

Joseph J. Levin -- Chief Counsel, NHTSA

ID: nht76-3.49

DATE: 03/15/76

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Bock Products, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your February 11, 1976, question whether two trailer designs you describe would qualify as "Heavy Hauler Trailer[s]" as defined in Standard No. 121, Air Brake Systems. A copy of that definition is enclosed for your information.

Both of your trailer designs include a primary cargo-carrying surface that inclines from a height of 24 inches in the rear to a height of 47 inches in the front of the trailer. In one case, part of the inclined portion is removable, leaving a 6-foot length of the surface that is flat and 40 inches above the ground in the unloaded condition. In both cases somewhat more than one-half of the primary cargo-carrying surface is 40 inches or less in height.

The exclusion from Standard No. 121 for heavy hauler trailers applies (in relevant part) only to trailers "whose primary cargo-carrying surface is not more than 40 inches above the ground in an unloaded condition." The trailer designs you describe would not qualify for the exclusion, because only a portion of the surface qualifies as "not more than 40 inches above the ground."

SINCERELY,

BOCK PRODUCTS, INC.

Feb. 11, 1976

Office of the Chief Council NHTSA

Att: M.J. Herlihy

Mr. Sydney Williams of NHTSA suggested we write for a ruling on the enclosed designs to see if they would be exempt from the FMVSS #121.

They appear to fall within the description of the "Heavy Hauler Trailer", in that the bed height is below 40" over the primary cargo carrying length of the trailer.

However, to be sure of our position we are in need of a ruling by your office.

These designs would be used in the recreational vehicle industry as transporters for manufacturers of travel trailers and mini-motor homes.

Design #2 describes a 6'-0" section of removable ramp which would be left in position when transporting their product. It would install by pins at both ends.

We require your immediate attention on this matter as a rush order is pending.

Robert Fisher Sales Engineer/Coordinator

PROPOSED DESIGN PROFILE #2

DATE: 2-10-76

BOCK PRODUCTS 1901 W.HIVELY AVE. ELKHART, IND. 46514

NOTE! GROUND HEIGHT DIMENSIONS SHOWN ARE UNLOADED HEIGHTS

(Graphics omitted)

PROPOSED DESIGN PROFILE #1

DATE: 2-10-76

BOCK PRODUCTS

1901 W. HIVELY AVE. ELKHART, IND. 46514

NOTE! GROUND HEIGHT DIMENSIONS SHOWN ARE UNLOADED HEIGHT

(Graphics omitted)

ID: nht73-1.21

DATE: 04/13/73

FROM: AUTHOR UNAVAILABLE; Robert L. Carter; NHTSA

TO: Mrs. Lewis Polin

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter to our Region III office in which you requested information on infant car seats and regulations affecting the manufacture of such seats.

Enclosure 1 is a copy of Federal Motor Vehicle Safety Standard No. 213, Child Seating Systems, along with a recent amendment to the standard. The effective date of this standard was April 1, 1971. All child car seats which both seat and restrain a child in a motor vehicle are now required by law to comply with the requirements of this standard. This regulation requires the date of manufacture to be placed on each seat along with recommendations for its use. Child seating systems are recommended for use by children from approximately eight to nine months to three to four years of age.

The National Highway Traffic Safety Administration is presently developing a proposed amendment to the existing standard which will require dynamic tests of all child restraints and will regulate infant restraints which are not presently covered by Standard No. 213. However, it is not anticipated that this amendment will become effective in the near future.

Enclosures 2 and 3 are copies of press releases notifying consumers of devices which have failed to pass Standard No. 213, and of the action the manufacturers are taking to correct the situation. Additionally, we are enclosing a copy of a consumer information booklet entitled, "What To Buy In Child Restraint Systems." We hope this information will assist you.

We do not endorse or advocate any specific product, but rather develop, issue, and enforce minimum safety standards for consumer protection. In the final analysis, the consumer should select a restraint which best fits his particular needs. Many practical considerations may affect the usage of a device, for example, the activity level of the child, portability of the device, and ease of attachment. These are all factors which the buyer of a child restraint system should consider in making his selection.

Thank you for your interest in motor vehicle safety.

Sincerely,

4 Enclosures

U.S. DEPARTMENT OF TRANSPORTATION

NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION

REGION III March 22, 1973

Mrs. Lewis Polin

1912 Nester Street

Philadelphia, Pennsylvania 19115

Dear Mrs. Polin:

We would like to thank you for your interest in highway safety. Your request for information concerning regulations enacted in regard to infant car seats, along with brand names of those manufacturers who have produced such products in conformance with these standards, has been forwarded to our Washington office, and they in turn will help you with obtaining the information you need.

Sincerely,

Vincent D. Walsh, Sr. -- Regional Administrator

ID: nht73-3.10

DATE: 01/11/73

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Nissan Motor Co. Ltd.

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of November 21, 1972, concerning the definition of "head impact area" in 49 CFR 571.3(b).

Your question is whether the lower portion of the dashboard depicted in your letter is within the head impact area. Without knowing the interior dimensions of the vehicle, we cannot give you a definite answer. We can, however, describe the circumstances under which the lower part of the dash might be within the head impact area.

Under paragraphs (a) through (c) of the definition, the test device is pivoted forward about specified centers until it contacts the vehicle. These contact points, which together comprise the head impact area, are divided into two groups, those above the lower line of the windshield glass (paragraph (b)), and those below (paragraph (c)). Although the measurement of the head impact area is a continuous process, the separation of the contact points into two groups was accomplished by paragraphs that are not parallel in structure. This has caused some confusion.

The intent of paragraphs (b) and (c) of the definition might have been expressed in a single paragraph, reading as follows:

With the pivot point to "top-of-head" dimension at each value allowed by the device and the interior dimensions of the vehicle, pivot the measuring device from a vertical position forward and downward through

all arcs in vertical planes to 90 degrees each side of the vertical longitudinal plane through the seating reference point, until the head form contacts an interior surface or until it is tangent to a horizontal plane 1 inch above the seating reference point, whichever occurs first.

In our opinion it would be appropriate for you to employ this procedure to determine whether any part of the lower dash pad in your drawing falls within the head impact area. The goal of your evaluation would be to determine whether it is possible for the test device to be pivoted downward so that it contacts the lower pad without first contacting the upper pad. If at a particular point the device contacts the upper pad, and if the device is at its minimum length of 29 inches and its pivot point is on the seating reference point, then the area of the lower pad directly beneath that contact point would not be contactable and would not be a part of the head impact area. If, however, there is a point at which the head form in its downward arc would miss the upper pad and contact the lower pad, the lower pad would at that point be within the head impact area. It is quite possible that some points on the lower pad would be within the head impact area, while others would not.

ID: nht95-1.65

TYPE: INTERPRETATION-NHTSA

DATE: February 14, 1995

FROM: Philip R. Recht -- Chief Counsel, NHTSA

TO: David O'Neil -- Hehr International Inc.

TITLE: None

ATTACHMT: ATTACHED TO 12/6/94 LETTER FROM DAVID O'NEIL TO PHILIP R. RECHT (OCC 10574)

TEXT: This responds to your inquiry about Federal Motor Vehicle Safety Standard No. 205, Glazing Materials, with respect to the labeling of glazing installed on transit buses. You stated that the passenger and driver side window glazing on certain transit bus es will be a glass-plastic composite consisting of 1/4 inch tempered glass with DuPont Spallshield 307 plastic laminated to the interior surface. You asked whether this glazing must be certified and marked as Item 15B/16B glazing or whether it is possib le to certify and mark the glazing as Item 2/3. You also asked whether taping the required cleaning instructions to the glazing satisfies the requirements of paragraph S5.1.2.10.

Question One: Must the glazing be certified and marked as Item 15B/16B or is it possible to certify and mark the glazing as Item 2/3?

The glazing described in your letter is tempered glass-plastic and therefore must be certified and marked as either Item 15B or 16B glazing. Item 2 and Item 3 glazing refers to glass, not glass-plastic glazing. It would be incorrect to certify and mark a glass-plastic item of glazing as glass.

Question Two: Does a label containing all required instructions which is taped to the glazing satisfy the requirements of paragraph S5.1.2.10?

Paragraph S5.1.2.10(a) states that

Each manufacturer of glazing materials designed to meet the requirements of S5.1.2.1, S5.1.2.2, S5.1.2.3, S5.1.2.4, S5.1.2.5, S5.1.2.6, S5.1.2.7, or S5.1.2.8 shall affix a label, removable by hand without tools, to each item of such glazing material. Th e label shall identify the product involved, specify instructions and agents for cleaning the material that will minimize the loss of transparency, and instructions for removing frost and ice, and at the option of the manufacturer refer owners to the veh icle's Owners Manual for more specific cleaning and other instructions.

S5.1.2.10(a) applies to your Item 15B/16B glazing since the glazing is required to comply with S5.1.2.6 or S5.1.2.8, S5.1.2.10(a) requires a manufacturer to "affix a label, removable by hand without tools . . . ." Taping the instructions to the glazing i s one way to affix a label to glazing that could be removed by hand without tools. Therefore, a manufacturer could comply with the requirements in S5.1.2.10(a) by taping the instructions to the glazing.

I hope this information is helpful. Please feel free to contact Marvin Shaw of my staff at this address or by telephone at (202) 366-2992 if you have any further questions or need additional information.

ID: nht72-2.42

DATE: 04/13/72

FROM: AUTHOR UNAVAILABLE; C. A. Baker for E. T. Driver; NHTSA

TO: The Budd Company

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of March 10, 1972, in which you presented a series of questions concerning the meaning of several requirements of Federal Motor Vehicle Safety Standard No. 121, "Air Brake Systems." Our reply deals with the questions in the order you asked them.

1. Your first question concerns the meaning of the statement in section S5.4 that "a brake assembly that has undergone a road test pursuant to S5.3 need not conform to the requirements on this section." To paraphrase your question, the quoted language means that if a given brake assembly is subjected to the road test, the same brake assembly with the used lining need not conform to the dynamometer requirements. Conformity to the dynamometer requirements will be determined by testing an identical brake assembly with new linings. The petitions for deletion of dynamometer testing would have made the road test the only test. The standard requires both tests, even though two sets of identical brakes will be used, and our statement that the petitions were denied is therefore correct.

2. You point out that the measurement interval used in S5.4.1.1 for determining average torque, which begins when a specified pressure is reached, differs from the interval specified in S5.4 for measuring deceleration, which begins with the onset of deceleration. Although we agree that you may need different instrumentation for measuring average torque and average deceleration, we do not agree that their is any conflict since average torque and average deceleration are not required to be measured at the same time. We consider the present method of measuring torque and deceleration to be the correct methods.

3. The typographical error in section S5.4.1.1, which you have correctly edited to read "Repeat the procedure six times, increasing the brake chamber air pressure by 10 psi each time," has been corrected by a revision in the March 29, 1972, Federal Register.

4, 5, 6. The requirements of S5.4.2, S5.4.2.1 and S5.4.3 concerning average deceleration rates should not be understood to mean that a manufacturer, in his own testing, must test at exactly that rate. It is advisable for him to test in a manner that offers assurance that the brakes will pass when tested in the manner specified in the standard. Typically, where a test value such as 9 fpsps is specified, manufacturers tend to use more adverse values in their own testing. Under the former wording of these sections, the compliance agency could have tested brakes at decelerations higher than the specified minimum, and it would have been much more difficult for a manufacturer to ascertain his "worst case" situation.

The notice proposing to amend the weight conditions for truck-tractors should be issued within the next two months.

ID: nht91-3.32

DATE: April 29, 1991

FROM: Paul Jackson Rice -- Chief Counsel, NHTSA

TO: Eric G. Hoffman -- Russell & Hoffman, Inc.

TITLE: None

ATTACHMT: Attached to letter dated 3-26-91 from Eric G. Hoffman to Harry Thompson (OCC 5892)

TEXT:

This responds to your letter of March 26, 1991, addressed to Mr. Harry Thompson, asking about a private school's use of "mini-vans which are designed to carry more than 10 passengers." Your letter was referred to our office for reply. You stated that the school has become aware of the National Traffic and Motor Vehicle Safety Act (Safety Act) and is concerned whether the operation of the vans is in compliance with applicable regulations under the Act. You asked a number of questions related to that concern.

I am pleased to have this opportunity to clarify the operation of Federal law as it applies to school buses. The National Highway Traffic Safety Administration (NHTSA) defines "school bus" as a motor vehicle designed for carrying 11 or more persons, including a driver, and sold for transporting students to and from school or school-related events. Therefore, the vehicles refered to in your letter would be considered school buses under federal law.

The National Highway Traffic Safety Administration (NHTSA) has issued Federal motor vehicle safety standards applicable to all new school buses. These standards impose obligations on the manufacturers and sellers of new motor vehicles, not upon the subsequent users of these vehicles. It is a violation of Federal law for any person to sell as a school bus any new vehicle that does not comply with all school bus safety standards. If your client believes that they have been sold noncomplying vehicles, and that the dealer knew of their intended use, the school should contact NHTSA's Office of Vehicle Safety Compliance, at the address given above, and inform them of the apparent violation of Federal law.

Without violating any provision of Federal law, a school may use a vehicle to transport school children, even if the vehicle does not comply with Federal school bus regulations. This is so because the individual States have authority over the activities of a user of a school bus. Since the various questions you ask assume that the Safety Act regulates users of school buses, we are unable to provide specific answers to those questions. To determine whether the private school your firm represents may use noncomplying vans, you must look to state law.

I must emphasize NHTSA's position that a vehicle meeting Federal school bus regulations is the safest way to transport students. I encourage the school your firm represents to give its most careful consideration to the possible consequences of transporting students in vehicles that do not comply with these regulations.

I hope you find this information helpful. If you have further questions, please contact Mary Versailles of my staff at this address or by telephone at (202) 366-2992.

ID: amphibious_vehicle6175

Mr. Paul Larkin
Compliance and Research Services, Inc.
1701 West Front Street
Plainfield, NJ 07063




Dear Mr. Larkin:

This is in response to your letter, in which you asked if an amphibious vehicle your client is seeking to import would be classified as a "motor vehicle."  As explained below, our answer is yes.

Title 49 U.S. Code 30112 prohibits the importation of any motor vehicle or motor vehicle equipment that is not certified to all applicable Federal motor vehicle safety standards."Motor vehicle" is defined at 49 U.S.C. 30102(a)(6) as:

[A] vehicle driven or drawn by mechanical power and manufactured primarily for use on the public streets, roads, and highways, but does not include a vehicle operated only on a rail line.

Vehicles equipped with tracks, agricultural equipment, and other vehicles incapable of highway travel are not motor vehicles.Certain vehicles designed and sold solely for off-road use (e.g., airport runway vehicles and underground mining vehicles) are not motor vehicles, even if they may be operationally capable of highway travel.

In your letter you stated that your client, Rodedawg International Industries, wishes to import for sale into the U.S. an amphibious vehicle.You stated that the vehicle, the Rodedawg, is designed for "off-road use only, and will be sold, advertised, and marketed as such.You also stated that the certificate of origin will include a statement noting that the vehicle is not designed for use on public roads.You listed various vehicle characteristics demonstrating the vehicles amphibious capabilities and further stated that it is equipped with a throttle stop that limits the maximum speed on roads to 25 miles per hour.

The agency has consistently stated that off-road capabilities alone do not remove a vehicle from the definition of a "motor vehicle" (See letter to Judith Jurin Semo, April 19, 1994).While relevant, vehicle distribution and declarations contained in the certificate of origin are not determinative.The statutory definition directs us to consider the vehicle as manufactured.

Aside from the amphibious nature of the vehicle, the Rodedawg as manufactured is not readily distinguishable from other motor vehicles that have off-road capabilities, e.g., sport utility vehicles.Sport utility vehicles are considered motor vehicles and are generally classified as multipurpose passenger vehicles under our regulations.

We also note that the manufacturers website advertises the Rodedawg as a sport utility vehicle (http://rodedawgsuv.com/index.html, visited July 23, 2005) and represents the vehicle as an automobile.

Based on the design of the vehicle the Rodedawg would be classified as a "motor vehicle". If you have any further questions, please contact Mr. Chris Calamita of my office at (202) 366-2992.

Sincerely,

Stephen P. Wood
Acting Chief Counsel

ref:571
d.1/24/06

ID: aiam4772

"Dear Mr. Blackwell: This is in response to your letter asking whethe a certain vehicle that you plan to export to the United States would be subject to the Federal Motor Vehicle Safety Standards. You state that Liquidus has 'designed a system' by customizing an existing road tanker for 'overhead' loading. The vehicle you plan to export would be used for 'aircraft de-icing storage' and 'loading of aircraft de-icing tarmac vehicles while in a fixed location.' The road tanker used in your system was originally built in Canada by a firm that has since gone out of business. I am pleased to have this opportunity to explain our statute and regulations to you. The National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1381 et seq., the Safety Act) authorizes this agency to issue safety standards for new 'motor vehicles' and new items of 'motor vehicle equipment.' Accordingly, your vehicle is subject to the safety standards only if it is considered within the definition of 'motor vehicle' under the Safety Act. Section 102(3) of the Safety Act (15 U.S.C. 1391(3)) defines a 'motor vehicle' as any vehicle driven or drawn by mechanical power manufactured primarily for use on the public streets, roads, and highways, except any vehicle operated exclusively on a rail or rails. We have interpreted this language as follows. Vehicles that are equipped with tracks or are otherwise incapable of highway travel are plainly not motor vehicles. Tractors and other agricultural equipment are also not motor vehicles. Further, vehicles designed and sold solely for off-road use (e.g., certain airport runway vehicles and underground mining vehicles) are not considered motor vehicles, even though they may be operationally capable of highway travel. In addition, items of mobile construction equipment which use the highways only to move between job sites and which typically spend extended periods of time at a single job site are not considered motor vehicles. On the other hand, vehicles that use the public roads on a necessary and recurring basis are motor vehicles. For instance, utility vehicles like the Jeep are plainly motor vehicles, even though they are equipped with special features to permit off-road operation. If a vehicle's greatest use will be off-road, but it will spend a substantial amount of time on-road, NHTSA has treated it as a motor vehicle. Further, if a vehicle is readily usable on the public roads and is in fact used on the public roads by a substantial number of owners, NHTSA has treated the vehicle as a motor vehicle. This finding was made with respect to dune buggies, notwithstanding the manufacturers' statements that the vehicles were not intended to be used on the public roads. NHTSA has also stated in many prior interpretations that even vehicles that will regularly be used on the public roads will not be considered motor vehicles for the purposes of the Safety Act, if the vehicles have a maximum attainable speed of 20 miles per hour (mph) or less and have an abnormal configuration that readily distinguishes them from other vehicles on the road. We would apply these principles to the vehicle identified in your letter as follows. Your letter stated that this vehicle will be immobilized after it reaches the airport. Assuming this immobilization occurs, this vehicle would appear to be designed and sold solely for off-road use, just like certain other airport runway vehicles. In this case, it would not be a motor vehicle, even though it is operationally capable of highway travel before the immobilization. However, if the vehicle were not subsequently immobilized, and were moved from airport to airport with only a limited stay at any job site, this vehicle might be considered a 'motor vehicle.' This conclusion would be even more likely if a significant percentage of the vehicle's purchasers were to use the vehicle by moving it from airport to airport, notwithstanding your company's intent that the vehicles not be so used. This situation would be analogous to the classification of dune buggies. I hope that this information is helpful. If you have any additional questions, please contact John Rigby of this office by mail at the above address or by telephone at 202-366-2992. Sincerely, Paul Jackson Rice Chief Counsel";

ID: aiam4162

Dear Mr. Reilly: Thank you for your letter enclosing correspondence from Mr. Dennis D Furr of Lansing, Michigan.; As we understand his letter, Mr. Furr contacted you to express hi concern about a Michigan state law which permits loading school buses up to 110 percent of the number of persons for which the bus has a rated seating capacity. He believes that installation of safety belts in school buses would reduce the likelihood that excessive numbers of children would be carried on each school bus seat.; You asked for information on Mr. Furr's suggestion for school bu safety belts. I am pleased to explain the two sets of regulations we have for school buses, both of which are relevant to school bus seating accommodations. Before I begin, I would like to note that in July 1985, we responded to an inquiry on Mr. Furr's behalf from U.S. Senator Donald W. Riegle, Jr., asking about requirements limiting school bus passenger capacities. In our response, we explained how manufacturers currently determine the passenger capacities of their school buses and that we know of no safety problem related to their calculations. A copy of our letter is enclosed for your information.; As explained in our letter to Senator Riegle, the first set o regulations we have for school buses, issued under the authority of the National Traffic and Motor Vehicle Safety Act, includes our motor vehicle safety standards which apply to the manufacture and sale of new school buses. Some of Mr. Furr's concerns involve one of those safety standards, Standard No. 222, *School Bus Passenger Seating and Crash Protection*, which specifies requirements for safety belts in small school buses. Standard No. 222 currently does not require safety belts for passengers in large school buses (those with gross vehicle weight ratings greater than 10,000 pounds) because large school buses are already required to provide high levels of protection to passengers through a concept called 'compartmentalization.' Compartmentalization requires that the interior of large buses be improved so that children are protected without the need to fasten safety belts. The seating improvements include higher and stronger seat backs, additional seat padding, and better seat spacing and performance. Our safety standards do require safety belts for passengers in smaller school buses since those buses do not offer the same protection as that provided by compartmentalization.; In his letter to you, Mr. Furr appears to be primarily concerned wit overloaded school buses and believes that safety belts would prevent schools from overcrowding school bus bench seats. We believe that this rationale for safety belts does not warrant a Federal requirement for belts on large school buses, since large school buses offer substantial protection to passengers and safety belts per se will not prevent users from overcrowding their buses. Thus, requiring safety belts in large school buses under Federal law would not assuredly lessen overcrowding of buses, and any possible improvement in seating accommodations would not be achieved.; On the other hand, we do not prevent States and local school district from ordering safety belts on their large school buses if they wish to do so. Thus, States may order school buses with safety belts if they believe this would reduce the likelihood that school buses would be overloaded. Issues relating to safety belts in large school buses are discussed in NHTSA's publication entitled, 'Safety Belts on School buses,' June 1985. I have enclosed a copy of the report for your information.; Our second set of regulations for school buses, issued under th highway Safety Act, consists of recommendations to the States for operating their school buses and applies to Federal funding of State highway safety programs. Those recommendations are found in Highway Safety Program Standard No. 17, *Pupil Transportation Safety* (copy enclosed, which Mr. Furr refers to as 'Federal Standard 17.' This 'standard,' or guideline, recommends that States provide seating accommodations of minimum specified dimensions for each school bus occupant and that States coordinate seating plans to eliminate standees. To reiterate, however, Program Standard No. 17 is a guideline for the States and its adoption is determined by the States. We have no reason to believe that Michigan has not evaluated thoroughly its pupil transportation needs in determining whether to implement the standard's recommendations.; I hope this information is helpful. Please let me know if we can be o further assistance.; Sincerely, Diane K. Steed