Interpretation ID: aiam3589
Specifications Engineer
Thomas Built Buses Inc.
1408 Courtesy Road
P. O. Box 2450
High Point
NC 27261;
Dear Mr. Tydings: This responds to your June 28, 1982, letter asking several question about the remanufacture of school buses using old chassis and new bodies.; In general, the use of a new body on an old chassis does not constitut the manufacture of a new motor vehicle. Accordingly, your responsibility as the individual making this modification would simply be to make sure that you do not render inoperative the compliance of the pre- existing vehicle with any of the safety standards with which it complied when it was manufactured and with which it complies at the time of your modifications, i.e., the new body (and the chassis) would have to comply with the same standards with which the old body complied (15 U.S.C. 1397).; In your first hypothetical, you would use a pre-April 1, 1977 chassis In this case the body that you would use would not have to comply with the school bus safety standards that became effective on that date. Seat spacing could be determined by the customer.; Secondly, you would use a post-April 1, 1977 chassis. In this case th vehicle would be required to continue to comply with those standards applicable to it at the time of its manufacture, which includes the school bus safety standards. Seat spacing would be limited in accordance with Standard No. 222.; Your third and fourth hypotheticals are the same as the two noted abov except that the buses involved are not school buses. Once again, the general rule prevails that the buses need not comply with new motor vehicle safety standards, but simply must not have their previous compliance with standards rendered inoperative by you.; Finally, as you indicated in your letter, you should transfer th certification label from the old vehicle to the modified vehicle if you are replacing the vehicle's body.; Sincerely, Frank Berndt, Chief Counsel