Interpretation ID: aiam1074
Associate Director
School Bus Manufacturers Institute
5530 Wisconsin Avenue
Suite 1220
Washington
DC 20015;
Dear Mr. Haransky: This is in response to the two petitions for rulemaking dated Februar 15, 1973, that you submitted with respect to safety standards applicable to school buses. In one you requested that future standards applicable to school buses become effective on January 1, rather than September 1 as is customary with respect to passenger car standards. Your second petition made a specific request that the effective date of the Bus Window Retention and Release Standard, No. 217, which is set at September 1, 1973, be delayed until January 1,1974. The reason you gave was that the normal model changeover period of the school bus industry is around the first of the year, while September 1 is in the middle of the peak production season.; Your first petition did not mention any specific standards, and i really a general request that the NHTSA take into account the normal model changeover period of the school bus industry in making effective date decisions. This request appears to be reasonable, and we will certainly consider that factor with respect to standards that are as yet unissued.; The situation is different, however, in the case of Standard No. 217 The standard was published on May 10, 1972, more than fifteen months before its effective date. We consider this standard to be a very important one from a safety standpoint. Furthermore, the public concern over the safety of school buses is at an extremely high level. It appears probable that school bus buyers, who have become very safety conscious, have been relying on this effective date in their purchasing decisions.; We have been given no evidence that this standard will requir extensive redesign and retooling, and even if it did, a four-month delay imposed only a few months before the scheduled effective date would hardly be ameliorative. We have no reason to disbelieve your statements concerning the normal changeover period of the industry, but surely at this late date the industry must have taken the imminent effective date of Standard 217 into consideration in its production planning.; In consideration of all these factors, we do not judge it to be in th public interest to grant a delay in the effective date of Standard 217 on the basis of the reason you have provided, namely, the normal production cycle of the industry. If you wish to provide more detailed information concerning technological or economic difficulties that may be caused by the effective date of this standard, we will be willing to consider it.; Sincerely, James E. Wilson, Acting Administrator