Interpretation ID: aiam2661
McCandlish
Lillard
Bauknight
Church & Best
4069 Chain Bridge Road
Fairfax
VA 22030;
Dear Mr. Loftus: This responds to your August 4, 1977, letter asking whether th remanufacture of a school bus using a new chassis and an old school bus body constitutes the manufacture of a new school bus subject to the new Federal school bus safety standards.; The National Highway Traffic Safety Administration has determined tha the manufacture of a vehicle using a new chassis and an old body is the manufacture of a new vehicle. (Part 571.7, Title 49, Code of Federal Regulations.) In this regulation the agency indicated that the only time that the remanufacture of a vehicle would be exempted from compliance with the new safety standards is when an old chassis is combined with a new body. In those situations, the vehicle is considered a used vehicle not subject to the standards.; In the case to which you refer, the combination of a new chassis and a old school bus body would require that you modify the bus body to comply with all of the Federal school bus safety standards in effect on the date of your manufacture of the new bus.; Sincerely, Joseph J. Levin, Jr., Chief Counsel