ID: nht94-1.5

TYPE: INTERPRETATION-NHTSA

DATE: 01/01/94 EST

FROM: Denise Davis

TO: Whom It May Concern

TITLE: NONE

ATTACHMT: Attached to letter dated 8/9/94 from John Womack to Denise Davis (Std. 205)

TEXT: To Whom it May Concern:

I was pulled over recently for the tinting in my car windows. I was told to have it checked and I would be issued a sticker for my window if the windows complied with the law.

I've been to the Window Tinting Store and was told they would not issue me a sticker because my windows were only allowing 20% sunlight through and the NEW law wants 35% sunlight through.

I'm therefore under the impression that I should have my tinting removed, which would be no problem if it were to be replaced by the proper tint at the same time as the removal took place. I was informed that I would have to cover this expense.

I paid approximately $ 450.00 to have my windows tinted seven years ago when I purchased my car. I don't have a problem with the Georgia Law. I am, however, unemployed and do not feel I should have to cover an expense for a law that came into being aft er my car was tinted unless the State of Georgia has funds set aside to replace the tinting in my car with the proper shade of tint.

If I had recently had my windows tinted in the wrong strength, I would gladly remove it because I would have been in error in the first place for having it done incorrectly and unlawfully. At the time my windows were tinted I was not breaking any law an d I don't feel I should be put to an additional expense to conform to a law put into effect at a later date.

Your help in this matter would be greatly appreciated.

ID: nht94-1.50

TYPE: Interpretation-NHTSA

DATE: February 10, 1994

FROM: John Womack -- Acting Chief Counsel, NHTSA

TO: David Shapiro -- RV Designer Collection, Woodbridge, Inc.

TITLE: None

ATTACHMT: Attached to letter dated 11/17/93 from David Shapiro to NHTSA Chief Counsel (OCC-9358)

TEXT:

This responds to your inquiry about the applicability of Standard No. 302, Flammability of Interior Materials to aftermarket products. You state that you are planning to market fabric window coverings such as drapes and fabric bedding such as bedspreads for use in recreational vehicles. In response to your request for confirmation that Standard No. 302 does not apply to aftermarket products, I am pleased to have this opportunity to explain our regulations to you.

By way of background information, NHTSA is authorized to issue Federal Motor Vehicle Safety Standards that set performance requirements for new motor vehicles and items of motor vehicle equipment. NHTSA does not, however, approve or certify any vehicles or items of equipment. Instead, the Safety Act establishes a "self-certification" process under which each manufacturer is responsible for certifying that its products meet all applicable safety standards. The agency periodically tests new vehicles an d items of equipment for compliance with the standards.

In response to your question, there are currently no Federal motor vehicle safety standards (FMVSS's) that directly apply to the products you wish to manufacture. Under the authority of the Safety Act, NHTSA has issued Standard No. 302, which specifies requirements for the flammability resistance of materials in the occupant compartment of new vehicles. However, Standard No. 302 would not apply to your products because that standard applies to new motor vehicles and not to aftermarket items of motor ve hicle equipment.

I note, however, that there are other Federal requirements that indirectly affect the manufacture and sale of your products. Under the Safety Act, your products are considered to be items of motor vehicle equipment. As a manufacturer of motor vehicle e quipment, you are subject to the requirements in S151-159 of the Safety Act concerning the recall and remedy of products with safety related defects. I have enclosed an information sheet that briefly describes those responsibilities. In the event that you or NHTSA determines that your products contain a safety-related defect, you would be responsible for notifying purchasers of the defective equipment and remedying the problem free of charge. I note that even though Standard No. 302 would not apply t o your product, the product's flammability characteristics could be relevant to whether it contained a safety related defect.

Manufacturers, distributors, dealers, and motor vehicle repair businesses are subject to S108(a)(2)(A) of the Safety Act, which states: "No manufacturer, distributor, dealer, or motor vehicle repair business shall knowingly render inoperative...any vehi cle or item of motor vehicle

equipment in compliance with an applicable Federal motor vehicle safety standard...." This section would prohibit any manufacturer, distributor, dealer, or repair business from installing your product in used vehicles if the effect of such installation was to render inoperative the compliance of the vehicle with any safety standard, including Standard No. 302.

The "render inoperative" prohibition of S108(a)(2)(A) does not apply to the actions of vehicle owners in adding to or otherwise modifying their vehicles or items of motor vehicle equipment. Thus, if your products were placed in vehicles by the vehicle o wners, your products would not need to meet any FMVSSs. Nevertheless, in the interest of safety, we suggest you consider conforming your product to a flammability resistance standard equivalent to Standard No. 302.

I hope this information is helpful. If you have any further questions about NHTSA's safety standards, please feel free to contact Marvin Shaw of my staff at this address or by telephone at (202) 366-2992.

ID: nht94-1.51

TYPE: Interpretation-NHTSA

DATE: February 10, 1994

FROM: John Womack -- Acting Chief Counsel, NHTSA

TO: Pat McCue -- Allied Service Systems Manufacturing

TITLE: None

ATTACHMT: Attached to letter dated 7/15/93 from Pat McCue to Ed Jettner (OCC-8962)

TEXT:

This responds to your letter to Mr. Ed Jettner of this agency concerning an occupant restraint system you have developed to protect medics and attendants in the back of ambulances. I apologize for the delay in our response.

The system consists of a vest worn by the attendant which is attached by a tether strap to the ambulance. During an August 23, 1993 phone call with Mary Versailles of my staff, you explained that the tether straps include retractors which lock during a crash. During this phone call you also stated that the back vest can be attached to two tethers on the vehicle wall adjacent to the bench seat, and that the front of the vest is attached to another tether on the opposite wall. You asked for advice on " how regulations are established and how products are tested to meet standards."

The National Traffic and Motor Vehicle Safety Act (the Safety Act) authorizes this agency to issue Federal motor vehicle safety standards applicable to new motor vehicles and new items of motor vehicle equipment. Section 108(a)(1)(A) of the Safety Act pr ohibits any person from manufacturing, introducing into commerce, selling, or importing any new motor vehicle or item of motor vehicle equipment unless the vehicle or equipment is in conformity with all applicable safety standards. NHTSA does not approv e motor vehicles or motor vehicle equipment, nor do we endorse any commercial products. Instead, the Safety Act establishes a "self-certification" process under which each manufacturer is responsible for certifying that its products meet all applicable safety standards.

NHTSA has exercised its authority to establish three safety standards that may be relevant to a vest and tether system for ambulance attendants. The first is Standard No. 208, Occupant Crash Protection, which sets forth requirements for occupant protect ion at the various seating positions in vehicles. Ambulances, which are classified as multipurpose passenger vehicles under our regulations, are required to have safety belts at each designated seating position. The second relevant standard is Standard No. 302, Flammability of Interior Materials. This standard specifies burn resistance requirements for materials used in the occupant compartment of motor vehicles, including ambulances. The third relevant safety standard is Standard No. 209, Seat Belt Assemblies, which sets forth strength, elongation, webbing width, durability, and other requirements for seat belt assemblies.

Standards No. 208 and No. 302 apply, with certain exceptions that are not relevant to your product, to vehicles and not directly to items of equipment. Thus, the vehicle manufacturer, and not the equipment manufacturer, is responsible for certifying com pliance to these standards.

Standard No. 209, however, applies to seat belt assemblies as separate items of motor vehicle equipment, regardless of whether the belts are installed as original equipment in a motor vehicle or sold as replacements.

Standard No. 209 defines a "seat belt assembly" as "any strap, webbing, or similar device designed to secure a person in a motor vehicle in order to mitigate the results of any accident, including all necessary buckles and other fasteners, and all hardwa re designed for installing such seat belt assembly in a motor vehicle." Thus, your vest and tether system would be considered a "seat belt assembly," and the manufacturer of the system would be required to certify that it complies with Standard No. 209 before it could be sold.

If the vest and tether system was installed as original equipment by the vehicle manufacturer, the vehicle manufacturer would be required to certify that the vehicle complied with all applicable safety standards with that equipment installed in the vehic le. If the device was added to a new ambulance prior to its first sale, e.g., by the dealer, the person who modified the vehicle would be an alterer of a previously certified motor vehicle and would be required to certify that, as altered, the vehicle c ontinues to comply with all of the safety standards affected by the alteration.

I note that in your phone conversation with Ms. Versailles, you stated that your ambulances do have safety belts on the bench seat, however, these do not provide the mobility needed by the attendants when they are caring for a patient. It is our underst anding that you intend the vest and tether system to supplement the original safety belts. If your vest and tether system were installed in addition to the safety belts required by Standard No. 208, and provided that the installation did not interfere w ith the required safety belts, such installation would not affect the compliance of the vehicle with Standard No. 208, since the standard's requirements would be fully met by the original belts.

After the first purchase of a vehicle for purposes other than resale, the only provision in Federal law that affects the vehicle's continuing compliance with an applicable safety standard is set forth in section 108(a)(2)(A) of the Safety Act. That sect ion provides that:

No manufacturer, distributor, dealer, or motor vehicle repair business shall knowingly render inoperative, in whole or in part, any device or element of design installed on or in a motor vehicle ... in compliance with an applicable Federal motor vehicle safety standard.

This provision would prohibit any of the named commercial entities from installing your system if such installation rendered inoperative the compliance of the vehicle with any applicable safety standard. For example, if the material used in your system did not meet the burn resistance requirements of Standard No. 302, installation of the system would render inoperative compliance with that standard. The render inoperative provision does not prohibit owners from modifying their vehicles, even if such m odification adversely affects the compliance of the vehicle with safety standards. However, this agency encourages vehicle owners not to make any modifications which would negatively affect the occupant

protection systems installed in their vehicles. Also, vehicle modifications by owners may be regulated by state law.

In addition to certifying that your vest and tether system complies with Standard No. 209, I urge you to exercise care in evaluating how effective this system would be in an actual crash situation. The original belt system supplied with the vehicle limi ts the motion of the occupant by keeping the occupant attached to the seat. Your system would have a dual purpose: allowing the attendant sufficient mobility to care for a patient and protecting the attendant in a crash. The tether on your system will not achieve this second purpose if it allows too much motion within the compartment.

You may wish to consult a private attorney familiar with the law in the State of Arizona regarding potential liability in tort for your business. I also note that every State provides for some degree of civil liability for consumer products and repair wo rk.

I have also enclosed an information sheet that identifies relevant Federal statutes and NHTSA standards and regulations affecting motor vehicle and motor vehicle equipment manufacturers, and explains how to obtain copies of these materials.

I hope you find this information helpful. If you have any other questions, please contact Mary Versailles of my staff at this address or by phone at (202) 366-2992.

ID: nht94-1.52

TYPE: Interpretation-NHTSA

DATE: February 11, 1994

FROM: Jerry L. Steffy -- Triumph Designs, Ltd.

TO: Taylor Vinson -- NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 3/16/94 from John Womack to Jerry L. Steffy (A42; Std. 108; Part 555)

TEXT:

Since I faxed you with my question regarding FMVSS 108 and ECE Reg. 20, I received Part 555 of 49 CFR from Luke Loy.

555.5 implies that we could apply for an exemption from FMVSS 108 for this headlamp since there exists "an equivalent overall level of motor vehicle safety." This is of course, if NHTSA recognizes the worthiness of the testing under ECE Reg. 20.

This exemption would only be for the first model year as afterwards we will change to a headlamp already FMVSS 108.

Can you please confirm for the if this is a route we can employ in this instance?

Best regards.

2-10-94 fax from J.L. Steffy to Taylor Vinson: Dear Taylor:

Luke Loy suggested that I contact you with a specific query I have. Recently, in Canada, we were able to use ECE Reg. 20 in lieu of FMVSS 108 for a particular headlamp system use. Is it possible to substitute ECE 20 for FMVSS 108 in the states in some instances? Of course the majority of our suppliers fulfill testing according to FMVSS 108 however, there are individual exceptions. Some cases may require significant investment in order to have individual cases comply, so it is important to know.

Best regards

ID: nht94-1.53

TYPE: Interpretation-NHTSA

DATE: February 14, 1994

FROM: John Womack -- Acting Chief Counsel, NHTSA

TO: Jane L. Dawson -- Specifications Engineer, Thomas Built Buses, Inc.

TITLE: None

ATTACHMT: Attached to letter dated 8/2/93 from Jane L. Dawson to Charlie Hott (OCC-9045)

TEXT:

This responds to your questions about a December 2, 1992, rule that amended Standard No. 111, Rear-view mirrors, by establishing field-of-view requirements around school buses (57 FR 57000). The rule amended Standard No. 111 to require a bus driver to b e able to see, either directly or through mirrors, certain specified areas in front of and along both sides of school buses. I apologize for the delay in responding.

Your first question asks: Are we required to certify that the mirror system HAS THE ABILITY to be adjusted for viewing of the cylinders by a 25th percentile female or to certify that the mirror system HAS BEEN adjusted?

Under the National Traffic and Motor Vehicle Safety Act, each new vehicle manufacturer must certify that its vehicle complies with the Federal motor vehicle safety standards (FMVSS's). NHTSA evaluates a vehicle's compliance with the safety standards usi ng the test procedures and conditions specified in the FMVSS's. Standard 111 requires that specified areas must be visible when viewed from the eye location of a 25th percentile adult female (S9, S13). The test procedures of S13 state that, when testin g a school bus, NHTSA will adjust an adjustable mirror to the eye location of a 25th percentile adult female before the test, in accordance with the manufacturer's recommendations (S13.3). Of course, to comply with Standard 111, the mirror will have to be able to be adjusted to the required location at the time NHTSA tests the vehicle.

Your second question asks: Are the outside rearview mirrors required to view the area straight down from the mirrors and 200 feet rearward?

In an October 21, 1993, telephone conversation with Marvin Shaw of my staff, you explained that you ask whether S9.2 of Standard 111 requires measurement beginning at the ground below the System A mirror (and extending at least 200 feet behind that plane ).

The answer is yes, the mirror must provide a view of the area straight down from that mirror and extending 200 feet rearward. Section S9.2 states that each school bus must have two outside rearview mirror systems: A System A driving mirror and a System B convex cross view mirror. The System A mirror on the left side of the bus is required by S9.2(b)(2) to provide a view of "the entire top surface of cylinder M in Figure 2, AND OF THAT AREA OF THE GROUND WHICH EXTENDS REARWARD FROM THE MIRROR SURFACE n ot less than 60.93 meters (200 feet)" (emphasis added).

Please note that the agency is currently reviewing a rulemaking petition in which Blue Bird Body Company has requested that the agency amend

Standard No. 111, with respect to System A driving mirrors.

I hope this information is helpful. Please feel free to contact Marvin Shaw at this address or by telephone at (202) 366-2992 if you have any further questions or need additional information.

ID: nht94-1.54

TYPE: Interpretation-NHTSA

DATE: February 14, 1994

FROM: Lawrence A. Beyer -- Attorney at Law

TO: Z. Taylor Vinson -- Office of Chief Counsel, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 3/7/94 from John Womack to Lawrence A. Beyer (A42; Std. 108)

TEXT:

This letter requests an opinion letter from your office concerning the re-importation of a certified vehicle.

My client wishes to re-import vehicles which were certified by the original manufacturer and purchased in the U.S. These vehicles would then be modified and sent back to the U.S. The vehicles in question are motorcycles which would then have a shell pl aced around it. The frame would be slightly modified and seating lowered to incorporate the design. However, my client would not knowingly render inoperative wholly or in part any device or element of design installed in accordance with the FMVSS.

On November 16, 1992, your office issued a letter regarding this matter. Please advise me if this letter is still your interpretation.

ID: nht94-1.55

TYPE: Interpretation-NHTSA

DATE: February 14, 1994

FROM: Gary D. March -- Director, Illinois Department of Transportation, Division of Traffic Safety

TO: John Womack -- Acting Chief Counsel, NHTSA

TITLE: Docket No. 88-21; Notice No. 3; 57 FR 49413, November 2, 1992

ATTACHMT: Attached to letter dated 3/24/94 from John Womack to Gary D. March (A42; Std. 217)

TEXT:

On November 2, 1992, NHTSA published a Final Rule which revised the minimum requirements for school bus emergency exits and improved access to school bus emergency doors. I am sure you would agree that the purpose of this rulemaking was to enhance the s afety of children being transported in school buses. The Docket states that this Final Rule is effective May 2, 1994. We at the Illinois Department of Transportation interpret this Docket to mean school buses manufactured on or after May 2, 1994 must c omply with these new standards.

In September of 1993, we were asked the following question by a school bus distributor here in Illinois:

Does the vehicle's "date of manufacture" correspond to the vehicle's chassis completion date or the vehicle's body completion date? In essence, he asked when do manufacturers have to comply with this Docket?

On September 27, 1993, Ms. Catherine Allen of my staff spoke to Mr. David Elias of NHTSA and asked him the above question. He indicated the date of manufacture is correlated to the vehicle's date of completion. The vehicle's date of completion correspo nds to the date when the body and chassis are combined to form a completed vehicle. Therefore, we interpreted that answer to mean vehicles "combined" on or after May 2, 1994 must comply with this Docket.

On February 2, 1994, Ms. Allen spoke to Ms. Jane Dawson of Thomas Built Buses and asked if school buses manufactured on or after May 2, 1994 would meet the new standards. She replied, "Only if the chassis was manufactured on or after May 2, 1994." She indicated multi-stage manufacturers have the option of choosing the chassis manufacture date, the body manufacture date or a date in- between for the effective date of new standards.

On February 3, 1994, Ms. Allen spoke to Mr. Charles Hott of NHTSA and asked him the same question. He confirmed what Ms. Dawson had said.

Therefore, according to Mr. Hott's interpretation, a school bus which clearly displays a June 1994, or later, date of manufacture will not need to meet the standards of Docket 88-21 if the chassis was completed prior to May 2, 1994.

Since we have received two different interpretations from Mr. Elias and Mr. Hott, we are asking for an official interpretation from the agency. Currently, school districts are in the process of taking bids on buses that will be

delivered and perhaps have bodies mounted after May 2, 1994 to chassis manufactured prior to May 2, 1994. Therefore, I am sure you can understand the necessity of a prompt and official interpretation by your office.

If you need any additional information from us, please contact Mr. Larry Wort at 217/782-4974 or Ms. Catherine Allen at 217/785-1181. I will appreciate your expeditious response.

ID: nht94-1.56

TYPE: Interpretation-NHTSA

DATE: February 14, 1994

FROM: Daniel T. Mason -- Product Development Engineer, Automotive Division, Avery Dennison

TO: Barbara Gray -- Office of Market Incentives, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 4/8/94 from John Womack to Daniel T. Mason (A42; Part 541)

TEXT:

The purpose of this letter is to ask for a ruling of the footprint requirements of the parts marking legislation, 541-Federal Motor Vehicle Theft Prevention Standard.

I am a Product Development Engineer working under Cliff Nastas for Avery Dennison. My question refers to the footprint feature of the label that appears under a UV light in the substrate after the label (illegible words).

Both Avery Dennison and (illegible word) supply parts marking labels to the automotive industry. Both have a florescent agent that migrates into the substrate once applied. Would a label that substitutes a florescent copy of the VIN instead of the whol e footprint of the label be in compliance to the federal legislation?

Please inquire for a ruling on this. I will follow up this letter with a phone call to discuss any questions you may have in the next couple weeks.

ID: nht94-1.57

TYPE: Interpretation-NHTSA

DATE: February 14, 1994

FROM: Lawrence A. Beyer, Esq.

TO: Z. Taylor Vinson, Esq. -- Office of Chief Counsel, NHTSA/DOT

TITLE: None

ATTACHMT: Attached to letter dated 4/11/94 from John Womack to Lawrence A. Beyer (A42; Part 591; Part 592)

TEXT:

This letter requests an opinion latter from your office concerning a determination made my OVSC regarding the importation of vehicles from Canada.

OVSC has allowed the importation of vehicles which conform to Canadian safety standards, and U.S. safety standards with the exception of "minor labeling requirements." These vehicles must be for the owner's personal use.

OVSC has interpreted "personal use" to exclude importations of vehicles by corporations for their corporation's personal use. For example, an individual moving to the U.S. would be allowed to import a vehicle, provided he had a statement from the manufa cturer that the vehicle complied with all FMVSS with the exception of labeling. However, a company moving to the U.S. with the identical vehicle and letter would be required to import the vehicle through the R.I. program, under bond, etc.

I agree that if the company was importing the vehicle for resale, the R.I. program is necessitated. I do not understand the distinction OVSC makes between individual personal use and corporate personal use.

Please provide me with an interpretation to settle this issue.

ATTACHMENT

PERMANENT IMPORTATION OF CANADIAN VEHICLES PERSONAL USE (Not included - vehicles owned by business or used in commerce)

If an individual has a letter from the manufacturer stating that a Canadian vehicle was manufactured to comply with the U.S. Federal motor vehicle safety, bumper and theft prevention standards (FMVSS), except minor labeling:

a. A letter is provided by our agency that it is satisfactory to import the vehicle under the Box 2 category on the declaration statement (Form HS 7). b. The HS-7 form must be completed with Box 2 checked and a copy of the manufacturers letter and our correspondence must be attached. c. If a manufacturers letter isn't available - a registered importer must be used. FOR SALE

Such vehicles have to be imported by a registered importer (The RI is not necessarily the owner. If the vehicle manufacturer provides a letter that the vehicles comply except for minor labelling, we will require:

a. An HS-7 form indicating the registered importer (RI) as the importer of records. A Box 3 entry will be required. b. A compliance package showing any modifications that were required including photos of the speedometer and Canadian certification label, DOT bond, and payment of appropriate fees. c. Warranty Insurance Policy

MANUFACTURERS LETTERS

Since we have previously made a determination about Canadian vehicles that was published in the Federal Register, if a manufacturers letter is not available, the process also falls into a Box 3 category. We will require all of the items listed above. I f a Canadian vehicle was built on or after September 1, 1989, if it is not on our approved-eligible vehicle list, and if the MANUFACTURER DOES NOT INCLUDE AUTOMATIC RESTRAINTS THAT COMPLY WITH STANDARD NO. 208, or any other crash survivability standard, a petition will be required and it will have to be entered as a Box 3 (formerly allowed for determination under Box 7).

HOWEVER If the vehicle is equipped with the necessary automatic restraints and other modifications required to meet U.S. Federal motor vehicle safety standards but the manufacturers letter is not available, the RI DOES NOT have to petition if it can verify ident icality with a car certified by its original manufacturer to meet the U.S. Standards by part numbers, drawings etc.

ID: nht94-1.58

TYPE: Interpretation-NHTSA

DATE: February 14, 1994

FROM: Richard Kreutziger -- Executive Director, New York State Business Distributor Ass'n, Inc.

TO: Walter Myers -- Attorney Advisor, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 3/28/94 from John Womack to Richard Kreutziger (Std. 217; USA 103(d)); Also attached to letter dated 2/20/87 from Erika Z. Jones to Martin V. Chauvin

TEXT:

I am following up on the fax that I sent to you dated January 12, 1994.

As of this date - I have not received a response, to the question that was raised during our verbal conversation, and which I requested a formal written response in the aforementioned fax.

Will greatly appreciate your follow-up with the written formal response.

Another question has developed pertaining to the implementation of FMVSS 217 (amended). New York State school bus regulations - Chapter VI transportation regulations - article 3 safety part 721 requires two side emergency doors on vehicles of greater th an 67 pupil capacity. New York State also - in the past has required the side emergency doors to be "to the rear of center of the passenger compartment?" - they have just recently amended their regulations to conform t the FMVSS as to location "as near center of passenger compartment" - and have also in my reading have required both the left and right side emergency doors in center - BUT not in the same body section. The question is raised by some of the manufacturers/distributors - can the right side emergency door be located to the rear of the passenger compartment?

TEXT OF RICHARD KREUTZIGER'S 1/12/94 FAX TO WALTER MYERS:

In a follow-up to our morning phone conversation of this date, I hereby formally request a written response (preferably by fax) to the point of discussion in reference to the ability of any individual state agency to require that an entity other than a p olitical sub-division of the state (such as a school district) had only to meet the requirements/standards/regulations of NHTSA and not added individual state regulations, even if such regulations exceed the federal standards.

Example: "ABC" Central School - is required in their purchase of a school bus to transport students to and from home to school - and/or to transport students to school sponsored events - such vehicle must meet the prescribed FMVSS and to further meet the individual state regulations that exceed the FMVSS.

"XYZ" Bus Company - has a contract with "DEF" school district to transport the school pupils of the district to and from home to school, and/or school sponsored events. Because this entity is not a political sub-division the

state enforcement agency relating to school bus regulations can not mandate that this private enterprise meet the state regulations that exceed the FMVSS - the only requirements for this private entity and their school buses are those that are mandated b y FMVSS.

I hope my interpretation of our phone conversation, reflects your