Interpretation ID: 7996
Vice President Engineering
Collins Industries, Inc.
421 East 30th Avenue
Hutchinson, KS 67502-2493
Dear Mr. Nash:
This responds to your letter to the Administrator, National Highway Traffic Safety Administration (NHTSA), received in this office on November 18, 1992, and your telephone conversation of November 30, 1992 with Walter Myers of this office, regarding the proper classification of an ambulance.
You indicated that Wheeled Coach Industries of Orlando, Florida, a subsidiary of Collins Industries, produces ambulances that are built on truck chassis. You stated that in the past those vehicles have been classified as trucks, but that Ford Motor Company auditors told you that they should be classified as multipurpose passenger vehicles (MPV). You said that you needed to know how to classify ambulances, observing that it appeared to you that the final stage manufacturer was free to choose between the two classifications, truck or MPV.
NHTSA has long considered ambulances to be multipurpose passenger vehicles, which are defined in 49 Code of Federal Regulations (CFR) 571.3 as "a motor vehicle with motive power, except a trailer, designed to carry 10 persons or less which is constructed either on a truck chassis or with special features for occasional off-road operation." Your company's ambulances fit this definition very well: they are mounted on a truck chassis and are designed to carry ten persons or less.
As you pointed out in your letter, it is true that an ambulance may carry more weight in special equipment than it carries in patients, and it may operate half its life with no patient on board. Nevertheless, NHTSA believes that whether or not a patient is on board or how much equipment is carried, the vehicle is primarily designed for the transportation and/or care of ill or injured persons, as well as the transportation of paramedic personnel to wherever they are needed. This is in contrast to a truck which is defined also in 49 CFR 571.3 as "a motor vehicle with motive power, except a trailer, designed primarily for the transportation of property or special purpose equipment". Thus, although an ambulance carries special purpose equipment, NHTSA believes that the equipment is only ancillary to the primary function of an ambulance which is the transportation of persons. Accordingly, an ambulance falls within the definition of MPV rather than truck.
I hope this will help clarify this issue for you. Should you have any further questions in this regard, please feel free to contact Mr. Myers at this address or at (202) 366-2992.
Sincerely,
Stephen P. Wood Assistant Chief Counsel for Rulemaking
ref:571 d.12/30/92