Interpretation ID: nht95-3.23

TYPE: INTERPRETATION-NHTSA

DATE: June 22, 1995

FROM: Douglas Miyashiro -- ATTB System Engineering, Northrop Grumman

TO: Dorothy Nakama -- NHTSA

TITLE: Clarification of Title 49, Part 581

ATTACHMT: ATTACHED TO 7/13/95 LETTER FROM JOHN WOMACK TO DOUGLAS MIYASHIRO (A43; REDBOOK 2; PART 581)

TEXT: Dear Ms. Nakama,

Thank you for your recent help in providing clarification on a previous issue regarding the FMVSS title 49 part 571. Currently, our system engineering department is defining design requirement for the Northrop Grumman Advance Technology Transit Bus (ATT B) program working in conjunction with the Federal Transit Authority. We have been researching bumper safety standard concerning any applicable federal regulation for transit buses. Title 49, part 581 is the only reference on the subject of bumper stan dard and it states the following:

Title 49, Part 581.3 states, "This standards applies to passenger motor vehicles other than multipurpose passenger vehicle."

We are requesting clarification regarding the word "passenger motor vehicles." We feel that this pertains only to a passenger car but request clarification if a bus is inclusive in the definition of a "passenger motor vehicle." We have reviewed all the d efinitions listed in the FMVSS (title 49 part 571) for all different variation to the specific types of vehicle.

We would appreciate a written response clarifying the word "passenger motor vehicle" in order to determine what our design requirements are.