Interpretation ID: 77-5.13

TYPE: INTERPRETATION-NHTSA

DATE: 12/21/77

FROM: JOSEPH J. LEVIN CHIEF COUNSEL

TO: JAMES TYDINGS -- THOMAS BUILT BUSES, INC.

TITLE: NOA - 30

ATTACHMT: ATTACHED TO LETTER DATED 08/26/88 TO R.C. ROST FROM ERIKA Z. JONES, REDBOOK A32, STANDARD 108; LETTER DATED 03/18/88 TO CHIEF COUNCIL -- NHTSA FROM R.C. ROST RE REQUEST THAT HEADSTART BUSES NOT BE REQUIRED TO HAVE ROOF WARNING LIGHTS IF A COLOR OTHER THAN SCHOOL BUS YELLOW IS USED, OCC-1763; LETTER DATED 02/11/88 TO SHANON L. FOND FROM JERRY SMITH RE FEDERAL INTERPRETATION OF SCHOOL BUS USER; LETTER DATED 02/25/88 TO SHARON FORD, FROM JERRY SMITH; UNDATED BROCHURES ON SCHOOL BUS BY WAYNE CORPORATION

TEXT: Dear Mr. Tydings:

This responds to your November 11, 1977, letter asking whether Head Start facilities are considered preprimary schools for purposes of applying the Federal school bus safety standards.

The National Highway Traffic Safety Administration (NHTSA) has determined that these facilities are primarily involved with the education of preprimary school children. Thus, the buses used to transport children to and from the Head Start facilities are considered school buses under the National Traffic and Motor Vehicle Safety Act (as amended by the Motor Vehicle and School Bus Safety Amendments of 1974) and must meet all Federal school bus safety standards.

Sincerely,