Interpretation ID: 77-3.14

TYPE: INTERPRETATION-NHTSA

DATE: 06/28/77

FROM: AUTHOR UNAVAILABLE; Joseph J. Levin, Jr.; NHTSA

TO: Collins Industries, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your May 6, 1977, question whether Safety Standard No. 301-75, Fuel System Integrity, is applicable to all school buses or only to school buses with a GVWR greater than 10,000 pounds.

You are correct in your statement that school buses are included in the broader classification, "buses", for purposes of the Federal motor vehicle safety standards, unless otherwise specified in a particular standard. Safety Standard No. 301-75 is applicable to passenger cars, and to multipurpose passenger vehicles, trucks and buses that have a GVWR of 10,000 pounds or less, including school buses under 10,000 pounds. The standard is also applicable to larger school buses, and the distinction is made in the standard since the large school buses are the only vehicles having a GVWR greater than 10,000 pounds that are covered by the standard.

Safety Standard No. 301-75 was made applicable to all school buses pursuant to a mandate under the Motor Vehicle and Schoolbus Safety Amendments of 1974 (15 U.S.C. 1392(i) (1) (A)).

SINCERELY,

COLLINS INDUSTRIES INC.

MAY 6, 1977

FRANK BERNDT ACTING CHIEF COUNCIL

FEDERAL MOTOR VEHICLE SAFETY STANDARDS AND REGULATIONS PART 571.301-7S-1 STATES THAT SCHOOL BUSES WITH GVWR GREATER THAN 10,000 POUNDS SHALL MEET THE REQUIREMENTS OF SECTION 6.5 OF 301. HOWEVER, SCHOOL BUSES BELOW 10,000 POUNDS GVWR ARE NOT SPECIFICALLY MENTIONED IN 301. I UNDERSTAND THAT ALL SCHOOL BUSES MUST MEET THE REQUIREMENTS OF BUSES IN GENERAL UNLESS STATED OTHERWISE IN FMVS STANDARDS. BY DEFINITION, A SCHOOL BUS IS A BUS. IS MY INTERPRETATION CORRECT ACCORDING TO NHTSA?

A REPRESENTATIVE OF ONE OF OUR CHASSIS SUPPLIERS CALLED TO MY ATTENTION THAT ONLY THE LARGE SCHOOL BUSES (OVER 10,000 GVWR) WERE MENTIONED IN 301. HE SEEMED TO BE UNDER THE IMPRESSION THAT THIS COULD BE CONSTRUED TO MEAN SCHOOL BUSES LESS THAN 10,000 GVWR ARE NOT INCLUDED IN 301.

I AM LOOKING FORWARD TO YOUR REPLY AND WILL APPRECIATE ANY INFORMATION YOU GIVE ME.

JAMES M. BEACH DIRECTOR OF ENGINEERING