Interpretation ID: aiam3807
EF Technology
1405 North U.S. 27
St. Johns
MI 48879-0189;
Dear Mr. Sprafka: This is to follow-up on your phone conversation with Stephen Oesch o my staff concerning the application of Standard No. 301, *Fuel System Integrity*, to a school bus that has a natural gas fuel system as original equipment. As discussed below, Standard No. 301 does not apply to a natural gas fuel system.; Standard No. 301 sets fuel system integrity requirements for certai vehicle types, including school buses with a gross vehicle weight rating of 10,000 pounds or more. The standard, however, only applies to those vehicles which use fuel with a boiling point above 32 degrees Fahrenheit. Since natural gas does not have a boiling point above 32 degrees Fahrenheit, the standard would not apply.; Although there are no safety standards applicable to natural gas fue systems, manufacturers are responsible for any safety-related defects in their motor vehicles or items of motor vehicle equipment. Section 151, *et seq*. of the National Traffic and Motor Vehicle Safety Act, a copy of which is enclosed, provide that manufacturers of motor vehicles and motor vehicle equipment must notify owners of vehicles and equipment with safety-related defects and remedy those defects free of charge.; I am also enclosing, for your information, an agency letter discussin the legal responsibilities of persons who converted gasoline fuel systems to use propane and other gas.; Sincerely, Frank Berndt, Chief Counsel