Interpretation ID: nht76-4.41
DATE: 03/26/76
FROM: AUTHOR UNAVAILABLE; R. B. Dyson; NHTSA
TO: Thomas A. Kirwan III - Capco
TITLE: FMVSS INTERPRETATION
TEXT: This is in response to your letter of February 25, 1976, requesting information concerning the Federal motor vehicle safety standards and regulations applicable to transit vehicles, specifically, Dodge vans that will be used in a rural transportation system.
The answers to your questions are as follows:
(1) "Which FMVSS apply to vans used in transit service?"
If your Dodge vans are designed to carry 10 persons or less they would qualify as "multipurpose passenger vehicles", as defined in 49 CFR Part 571.3. As multipurpose passenger vehicles, the Dodge vans would be subject to the requirements of the Federal Motor Vehicle Safety Standards listed below. The standards marked with an asterick (*) are equipment standards and do not apply to the vehicles themselves. Rather, these standards set forth requirements for manufacturers of motor vehicle equipment for use in multipurpose passenger vehicles.
No. 101 - Control Location, Identification, and Illumination.
No. 102 - Transmission Shift Lever Sequence, Starter Interlock, and Transmission Braking Effect.
No. 103 - Windshield Defrosting and Defogging Systems.
No. 104 - Windshield Wiping and Washing Systems.
*No. 106-74 - Brake Hoses.
No. 107 - Reflecting Surfaces.
No. 108 - Lamps, Reflective Devices, and Associated Equipment.
No. 111 - Rearview Mirrors.
No. 112 - Headlamp Concealment Devices.
No. 113 - Hood Latch System.
*No. 116 - Motor Vehicle Brake Fluids.
No. 118 - Power Operated Window Systems.
*No. 119 - New Pneumatic Tires for Vehicles Other Than Passenger Cars.
No. 120 - Tire Selection and Rims for Vehicles Other than Passenger Cars.
No. 124 - Accelerator Control Systems.
*No. 125 - Warning Devices.
*No. 205 - Glazing Materials.
No. 206 - Door Locks and Door Retention Components.
No. 207 - Seating Systems.
No. 208 - Occupant Crash Protection.
*No. 209 - Seat Belt Assemblies.
No. 210 - Seat Belt Assembly Anchorages.
No. 211 - Wheel Nuts, Wheel Discs and Hub Caps.
No. 213 - Child Seating Systems.
No. 219 - Windshield Zone Intrusion.
No. 301-75 - Fuel System Integrity.
No. 302 - Flammability of Interior Materials.
The manufacturer of the Dodge vans must affix a label to each vehicle certifying that the vehicle is in compliance with all applicable Federal motor vehicle safety standards and regulations, as required by 49 CFR Part 567, Certification. This certification label should be affixed to the door or door post of each vehicle, and you should check to make certain that it is present.
Please note that if the Dodge vans are designed to carry more than 10 persons, they would be classified as "buses" under 49 CFR Part 567.3, and the list of applicable safety standards would differ.
(2) "Does NHTSA recommend a set of vehicle specifications for vans used in transit?"
No. The NHTSA has issued only the requirements found in the motor vehicle safety standards and regulations.
(3) "Do any FMVSS apply specifically to modified vans (e.g. those filled with hydraulic lift for wheelchairs and a raised roof)?"
No. Such vehicles must meet the same standards as other MPV's.
(4) "Are there any regulations which apply to fiberglass bubbletops on vans in transit service?"
Yes. Motor Vehicle Safety Standard No. 205, Glazing Materials, 49 CFR 571.205, specifies requirements for glazing materials for use in motor vehicles and motor vehicle equipment. Rigid plastic materials that are to be used as covers for openings in the roof of a vehicle must conform to the requirements specified in paragraph S5.1.2.1 of Standard No. 205.
(5) "Are there any regulations, perhaps within the Federal Highway Safety Act, which apply to driver qualifications?"
Yes. Driver qualifications for transit vehicles are governed by Federal Motor Carrier Safety Regulations, 49 CFR Part 391, Qualifications of Drivers.
(6) "Could you provide any further information which you feel would contribute to the safe operation of our transit system?"
At the present time the NHTSA has not issued any general guidelines concerning the organization or operation of transit systems. You may, however, wish to contact the Urban Mass Transportation Administration of this Department for information on this subject.
I hope this letter has been responsive to your questions. Please contact us if we can of any further assistance.
Yours truly,
ATTACH.
CAPCO
February 25, 1976
National Highway Traffic Safety Administration
Gentlemen:
The Capital Area Planning Council is in the process of implementing a rural transportation system as part of the Federal Highway Administration's Rural Highway Public Transportation Demonstration Program (Section 147 of the Federal Aid Highway Act of 1973). We are, therefore, interested in obtaining information concerning vehicle specifications and safety standards for transit vehicles.
Since our transit fleet will be entirely composed of Dodge vans rather than standard transit buses, we are uncertain as to which Federal Motor Vehicle Safety Standards apply specifically to vans used in transit operations. Could you assist us by providing the answers to the following questions:
1) Which FMVSS apply to vans used in transit service?
2) Does NHTSA recommend a set of vehicle specifications for vans used in transit?
3) Do any FMVSS apply specifically to modified vans (e.g. those fitted with hydraulic lift for wheelchairs and a raised roof)? 4) Are there any regulations which apply to fiberglass bubbletops on vans in transit service?
5) Are there any regulations, perhaps within the Federal Highway Safety Act, which apply to driver qualifications?
6) Could you provide any further information which you feel would contribute to the safe operation of our transit system.
Enclosed is a draft of our vehicle specifications. I would appreciate your comments and suggestions prior to March 10 so the necessary revisions may be made before our public hearings begin.
Yours very truly,
Thomas A. Kirwan III -- Transportation Planning Intern
Enclosure
Vehicle Specifications (Minimum Requirements)
1 ton - 125" wheelbase 350 cu. in. 8 cyl. engine 7400 lbs. GVW Min. Front Axle 3300 lbs., Rear Axle 5050 lbs. Automatic Transmission Power Disc Brakes Power Steering Heavy Duty Front/Rear Shock Absorbers Heavy Duty Front/Rear Springs Heavy Duty Alternator Heavy Duty Battery Heater (High Capacity) Air Conditioning (High Capacity) - 22,000 B.T.U. Slant Line or Vented Tinted Glass Windows Gauges - Oil Pressure and Ammeter Lighting Package (Door Actuated) Exterior Lighting to meet F.M.V.S.S. Insulation Package Undercoating Dual Electric Horn and Horn Bar Large Lo-Mount Side Mirrors Seat Belts for all Passengers Two Speed Electric Wipers and Window Washer Exhaust Emission Controls to meet F.M.V.S.S. and State Code High Capacity Fuel Tank Tires 8.00 x 16.5 (10 Ply Truck Type or Steel Radial) Front Stabilizer Bar Oil Filter - 1 Quart Freight, Handling, and Dealer Preparation
Modifications
Raised, Collapse Resistant Steel Roof Cap Restructured, penetration resistant sidewalls, and rear end sections Gas Tank Shield Drive Shaft Guards Passenger Door Entrance Heavy Duty Driver Door Control (manual) Entrance Door and Front Section Padding Passenger Grab Rails Two Leaf Side Door (Extended Doorway) Electric Hydraulic Lift, Expanded Metal Ramp, Semi-Automatic/Manual Override (minimum lift capacity 500 lbs.) Wheelchair Tie Downs (2 prs. mounted at 45 degrees) Rubber Non-Skid Flooring First Aid Kit 2 3/4 lbs. - 10 BC Dry Chemical Fire Extinguisher Reflector Flare Kit