Interpretation ID: nht95-2.86

TYPE: INTERPRETATION-NHTSA

DATE: May 18, 1995

FROM: Jim Burgess -- Engineering Manager, Independent Mobility Systems, Inc

TO: Walter Myers -- Chief Council, NHTSA

TITLE: NONE

ATTACHMT: ATTACHED TO 8/4/95 LETTER FROM JOHN WOMACK TO JIM BURGESS (A43; REDBOOK 2; STD. 206)

TEXT: Dear Mr. Meyers:

Per our conversation earlier today, I am writing to learn your interpretation of 49CFR, 571.206, S4, as it pertains to our vehicles.

As we discussed, for eight (8) years, Independent Mobility Systems, Inc., has been converting Chrysler minivans, and recently Ford minivans, into wheelchair accessible vehicles by lowering the floor and adding a wheelchair ramp in the passenger side rear sliding door area. We have crash tested these converted vehicles at OTRC in Ohio for FMVSS 571.208 Frontal Impact, and for FMVSS 571.301 Rear Impact and Side Impact, to gain certification.

In regard to 49CFR, 571.206, S4, our interpretation is that side doors on motor vehicles which are equipped with wheelchair lifts, and linked to an alarm system consisting of either a flashing visible signal located in the driver's compartment or an alar m audible to the driver which is activated when the door is open, need not conform to this standard, pertains to our converted vehicles. We believe the wheelchair ramp we employ serves the same function as a wheelchair lift, in that it provides those per sons in wheelchairs or access to the vehicle, and thus we do not have to conform to this standard.

Because we have had inquiries from customers on this issue, your written interpretation to our inquiry will be appreciated.

ENCLOSURE

June 16, 1995

Dear Mr. Meyers:

As per our telephone conversation this morning, I am sending the enclosed brochures on our current offerings. As I stated, we are working on converting the new 1996 Chrysler NS minivans. We are scheduled for crash testing this vehicle the latter part o f July and offer it for sale in mid-August.

If you have any further questions before ruling on our request of May 18, 1995, regarding interpretation of 49 CFR, 571.206, S4, please call me.

Sincerely,

INDEPENDENT MOBILITY SYSTEMS, INC.

Jim Burgess Engineer

Enclosure: RAMPVAN BROCHURE/PHOTOS OMITTED