Interpretation ID: aiam3621
Superintendent
Thatcher Unified Schools
District No. 4
P.O. Box 610
Thatcher
AZ 85552;
Dear Mr. Peck: This is in response to your letter of September 30, 1982, enclosing 'petition for exemption...on behalf of Capps and Lancaster Service Center'. The petition concerns a single motor vehicle consisting of the body of a 1974 Dodge school bus which has been removed from its original chassis and attached to a new 1981 International Harvester chassis.; This agency does not regulate the use of motor vehicles. That is matter for State governments. We do enforce the Federal motor vehicle safety standards and grant exemptions as appropriate consistent with our authority.; I regret that the exemption process is not available in your case. Par 555 is intended to cover the future vehicle production of bona fide motor vehicle manufacturers, and not a single conversion, performed in the past, by what appears to be a service garage. Under our regulations, the combination of an old body upon a new chassis results in a new motor vehicle required to meet the motor vehicle safety standards in effect when the chassis was manufactured. Compliance is especially important in this instance because of all the school bus safety standards that have become effective since the bus body was manufactured in 1974, and which affect its structure and that of its seats.; This means that Capps and Lancaster are technically in violation of th National Traffic and Motor Vehicle Safety Act, for which a penalty of up to $1000 may be imposed. We do not intend to pursue this, however, unless other violations come to our attention. However, our Office of Vehicle Safety Compliance will be contacting Capps and Lancaster to make them aware of their responsibilities in order to prevent further violations by that company.; Sincerely, Frank Berndt, Chief Counsel