Interpretation ID: 86-2.27

TYPE: INTERPRETATION-NHTSA

DATE: 04/21/86

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Ernest Farmer -- Director of Pupil Transportation, Tennessee Dept. of Education

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. Ernest Farmer Director of Pupil Transportation Tennessee Department of Education Nashville, Tennessee 37219-5335

This responds to your February 19, 1986 letter to the National Highway Traffic Safety Administration (NHTSA) asking whether Federal motor vehicle safety standards prohibit commercial businesses from using fiberglass on the exterior of school buses. As explained below, the answer to your question is no.

The National Traffic and Motor Vehicle Safety Act authorizes NHTSA to issue minimum performance standards for school buses. Our safety standards do not specify the materials to be used for the exterior of school buses. However, the materials chosen by a manufacturer must be strong enough to enable the bus to meet the requirements of those standards. Among those requirements are the rollover protection ones of Standard No. 220, fuel system requirements of Standard No. 301, and strength requirements of Standard No. 221, School Bus Body Joint Strength, for body panel joints on school buses with gross vehicle weight ratings over 10,000 pounds. Manufacturers of new school buses using fiberglass for school bus exteriors must certify that their vehicles conform to the requirements of all applicable school bus safety standards.

I hope this information is helpful. Please contact my office if you have further questions.

Sincerely,

Erika Z. Jones Chief Counsel

February 19, 1986

Ms. Deadra Holm U. S. Department of Transportation NHTSA 400 Seventh Street, S.W. Washington, D. C. 20590

Dear Ms. Holm,

We have discovered the presence of fiber glass in the outer skin of the Van Conversions manufactured by the Collins Industries Inc. of Hutchinson, Kansas. While, admittedly, we see little if any, safety hazard associated with the practice, we do forsee the possibility of legal actions "down the road" if children are seriously injured and the presence of this material is exposed.

Our school bus specifications require compliance with the National Minimum School Bus Standards as well as all Federal Motor Vehicle Safety Standards applicable to the manufacture, sale and operation of pupil transportation equipment. My question is: Does the use of fiberglass in the manufacture of Type II school buses conflict with any known FMVSS?

An early response will be appreciated.

Sincerely yours,

Ernest Farmer Director of Pupil Transportation