Interpretation ID: aiam3549
American Transportation Corporation
Highway 65 South
Conway
AR 72032;
Dear Mr. Ryan: This responds to your February 27, 1982, letter asking whether vehicle which transports 10 or fewer persons could be classified as a bus if it is built with a traditional bus body. The vehicle transports fewer persons than normal, because it is designed for wheelchair occupants. The answer to your question is no.; The classification of a vehicle as a bus or a multipurpose passenge vehicle for the purposes of the Federal motor vehicle safety standards depends upon its passenger capacity. See the definitions of 'bus' and 'multipurpose passenger vehicle' in 49 CFR 571.3. A vehicle that transports the number of persons that you mentioned in your letter must be classified as a multipurpose passenger vehicle. The fact that the vehicle is designed as a bus has no relevance to its classification. The controlling factor is passenger capacity.; Since the vehicle would be a multipurpose passenger vehicle, it woul be required to comply with all of the standards applicable to those vehicles. This would include compliance with Standard No. 206, *Door Locks and Door Retention Components*.; Sincerely, Frank Berndt, Chief Counsel