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Interpretation ID: nht93-2.5

DATE: March 3, 1993

FROM: Matthew J. Ryan -- Director, Commercial Vehicle Safety Bureau, State of New York, Department of Transportation

TO: Charles R. Hott -- Office of Vehicle Safety Standards, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 4-19-93 from John Womack to Matthew J. Ryan (A41; Std. 222)

TEXT: This letter is a follow-up to your telephone conversation today with Jim Brunet regarding interpretation of the recent changes (Federal Register 1/15/93) to Title 49 Part 571.222.

From your conversation, we feel the following statements are correct:

1. If a school bus is built or modified to accommodate one or more wheelchairs, after January 17, 1994, the restraint/securement system required by the regulation change, must be complied with.

2. A school bus built with no wheelchair seating positions, is not required to have a wheelchair position.

We request that you please confirm in writing that the above statements are accurate.

Thank you for your assistance in this matter and please feel free to contact us on (518) 457-3406, if you have any questions.