Interpretation ID: nht87-2.32

TYPE: INTERPRETATION-NHTSA

DATE: JULY 7, 1987

FROM: EAST, MORRIS -- ASSISTANT DIRECTOR-LOUISIANA BUREAU OF SCHOOL TRANSPORTATION

TO: ERIKA Z. JONES -- CHIEF COUNSEL-NHTSA

TITLE: NONE

ATTACHMT: ATTACHED TO MARCH 16, 1988 LETTER FROM JONES TO EAST

TEXT: This request for an opinion concerns the interpretation of the Federal Motor Vehicle Safety Standards that apply to school buses.

One of our local school systems has requested an opinion with respect to the changing of a school bus body from one chassis frame to another chassis frame. As we understand it, they intent to remove the bus body from an existing chassis and and place tha t body onto a new chassis. The work would be performed by the local school system's school bus maintenance shop. The shop has the facilities to perform most bus body repairs. We fully understand that Congress has placed the responsibility for overseei ng the manufacture of school buses with the National Highway Traffic Safety Administration. Therefore, we are asking for an opinion from your office concerning this matter. Specifically we need an answer to the following questions:

1. Is is permissible under the Traffic and Motor Vehicle Safety Act of 1966 and the Motor Vehicle and School Bus Safety Amendments of 1974 for a local school board to remove the body from one school bus chassis and place that body on another school bu s chassis? Would this action violate bus body integrity requirements of Federal Motor Vehicle Safety Standards (FMVSS) (specifically FMVSS 208, 220 and 221)?

2. If permitted, can the work described in 1. above be performed in the school board's maintenance shop? Can it be contracted to an automobile dealer capable of performing such work? Can the work be contracted to other motor vehicle repair shops su ch as bus body dealers or private motor vehicle repair shops?

3. If the changeover is allowed, must the new unit (new chassis with used body) be re-certified to meet FMVSS requirements? If it must be re-certified, who may provide the inspection and re-certification?

Your timely answer to the above questions will assist us in expediting our response to the local school board and will be greatly appreciated.