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Interpretation ID: 2909yy

Mr. Rueben K. Brown
Product Engineer
Crane Carrier Company
P.O. Box 582891
1925 North Sheridan
Tulsa, OK 74158

Dear Mr. Brown:

This responds to your letter of March 12, 1991 requesting an interpretation of the applicability of the spike stop requirement in Standard No. 105 to school buses with GVWR greater than 10,000 lbs. While school buses are required by S5.1 to be capable of meeting the requirements of S5.1.1 through S5.1.6, the spike stop requirement in S5.1.6 is only applicable to vehicles with a GVWR of 10,000 lbs. or less. Therefore, school buses with a GVWR greater than 10,000 lbs are not required to be capable of meeting the spike stop requirement.

I hope this information has been helpful. If you have further questions, please contact Mary Versailles of my staff at this address or by telephone at (202) 366-2992.

Sincerely,

Paul Jackson Rice Chief Counsel ref: 105 d:3/29/9l