Interpretation ID: 1982-2.4

DATE: 04/15/82

FROM: FRANK BERNDT -- CHIEF COUNSEL, NHTSA; SIGNATURE BY STEPHEN P. WOOD

TO: Auto Safety House

TITLE: FMVSR INTERPRETATION

TEXT: This responds to your March 25, 1982, letter asking whether an old school bus body can be mounted on a new chassis if the resulting vehicle would not comply with the safety standards applicable to school buses (Standards 220, 221 and 222). The answer to your question is no.

The agency regards the installation of a new chassis on a school bus as constituting the manufacture of a new school bus. Accordingly, the new school bus would be required to comply with the safety standards in effect on the date of its manufacture. In the case to which you refer, that would include compliance with all of the current school bus safety standards.

SINCERELY,

AUTO SAFETY HOUSE

March 25, 1982

Administrator National Highway Traffic Administration.

Subject: Certification

Gentlemen,

What standards does a school bus body built prior to 1977 have to meet when installed on a 1982 school bus chassis? Can this body be installed on a 1982 chassis without meeting Standards, 220, 221 and 222 that apply to bodies built after 1977?

I would appreciate receiving this information as soon as it can be processed and thank you in advance for your assistance.

Wilmer E. Harper President