Interpretation ID: aiam3405
Severy
Incorporated
2233 El Segundo Boulevard
El Segundo
CA 90245;
Dear Mr. Schultz: This responds to your recent letter asking whether a 4-wheel driv pickup truck must comply with Safety Standard No. 216, *Roof Crush Resistance*. You also ask whether the definitions of vehicle classification under Federal regulations are mutually exclusive.; The application section of Safety Standard No. 216, section 3 specifies that the standard applies to passenger cars. This means that the standard applies *only* to passenger cars. Therefore, the standard does not apply to a pickup truck.; The definitions of the basic vehicle classifications found in 49 CF Part 571.3 are mutually exclusive. If a vehicle falls within the definition of a 'truck,' the vehicle is not also within the definition of a 'passenger car.' The definition of a passenger car does not specifically exclude trucks because the definition is based on the function of the vehicle. Thus, a passenger car is defined as a motor vehicle designed for carrying persons. A truck, on the other hand, is defined as a vehicle designed primarily for the transportation of property or special purpose equipment. Since a pickup is designed primarily for carrying property and not persons, it is a truck and not a passenger car. Each motor vehicle has a certification label attached to its door which specifies the vehicle's classification.; I hope this has clarified any questions you had concerning vehicl classification under the Federal Motor Vehicle Safety Standards.; Sincerely, Frank Berndt, Chief Counsel