Interpretation ID: 1984-1.23

TYPE: INTERPRETATION-NHTSA

DATE: 03/15/84

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: EF Technology

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. Robort Sprafka EF Technology 1405 North U.S. 27 St. Johns, MI 48879-0189

Dear Mr. Sprafka:

This is to follow-up on your phone conversation with Stephen Oesch of my staff concerning the application of Standard No. 301, Fuel System Integrity, to a school bus that has a natural gas fuel system as original equipment. As discussed below, Standard No. 301 does not apply to a natural gas fuel system.

Standard No. 301 sets fuel system integrity requirements for certain vehicle types, including school buses with a gross vehicle weight rating of 10,000 pounds or more. The standard, however, only applies to those vehicles which use fuel with a boiling point above 32oF. Since natural gas does not have a boiling point above 32oF, the standard would not apply.

Although there are no safety standards applicable to natural gas fuel systems, manufacturers are responsible for any safety-related defects in their motor vehicles or items of motor vehicle equipment. Section 151, et seq. of the National Traffic and Motor Vehicle Safety Act, a copy of which is enclosed, provide that manufacturers of motor vehicles and motor vehicle equipment must notify owners of vehicles and equipment with safety-related defects and remedy those defects free of charge.

I am also enclosing, for your information, an agency letter discussing the legal responsibilities of persons who converted gasoline fuel systems to use propane and other gas.

Sincerely,

Frank Berndt Chief Counsel

Enclosures