Interpretation ID: aiam2542
Townsend & Townsend Attorneys at Law
P.O. Box 366
111 W. Second Street
Parsons
TN 38363;
Dear Mr. Townsend: This responds to your February 9, 1977, letter in which you ask how th National Highway Traffic Safety Administration determines whether a school bus must comply with the new school bus safety standards.; On April 1, 1977, several new standards will become effective relatin to the construction of school buses: Standard No. 220, *School Bus Rollover Protection*, Standard No. 221, *School Bus Body Joint Strength*, and Standard No. 222, *School Bus Passenger Seating and Crash Protection*. Further, several old standards have been amended to provide special requirements for school buses. These amendments also become effective on April 1.; Section 108(a)(1)(A) of the National Traffic and Motor Vehicle Safet Act (Pub. L. 89-563), as amended (Pub. L. 93-492), prohibits the manufacture for sale, sale, offer for sale, or introduction or delivery for introduction into interstate commerce of any motor vehicle or item of motor vehicle equipment manufactured on or after the date any applicable Federal motor vehicle safety standard takes effect that does not conform to the standard. This means that any school bus manufactured on or after April 1, 1977, must comply with the school bus safety standards, regardless of the date on which the bus is actually sold or introduced into interstate commerce.; For vehicles that you complete by mounting a body on a new chassis, yo are permitted to choose as the date of manufacture either the date of manufacture of the incomplete vehicle (as defined in Part 568, *Vehicles Manufactured in Two or More Stages*), the date of final completion of the vehicle, or a date between those two dates. Only those standards in effect on the date chosen to represent the date of manufacture would be applicable to the vehicle, irrespective of the date upon which the vehicle is sold to the ultimate consumer.; I am enclosing copies of the new school bus safety standards and Par 568 for your information.; Sincerely, Frank Berndt, Acting Chief Counsel