Interpretation ID: 86-1.20

TYPE: INTERPRETATION-NHTSA

DATE: 02/03/86

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Patrick R. McCreary -- General Manager, Van Patton Vans

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. Patrick R. McCreary General Manager Van Patton Vans 22865 Pine Creek Road P.O. Box 1305 Elkhart, IN 46515

This responds to your recent letter concerning the manufacturing operations you intend to perform on Ford Econoline vans. In a December 16 telephone conversation with Ms. Hom of my staff, you explained that the vans are incomplete vehicles which you will be receiving from a Ford dealership prior to the vehicles' first sale. A company other than your own will "stretch" the vehicle 48 to 60 inches, but your company will be completing the manufacture of the vehicle by adding seats (for 20 passengers), windows, carpeting, and so forth. You asked what your responsibilities would be under NHTSA's regulations and safety standards. Under our regulations, a motor vehicle designed for carrying more than 10 persons is a "bus" (Part 571.3). Since the vans, as completed, will meet that definition, the applicable safety standards for the vehicle you will be producing are those applying to buses. If you are performing manufacturing operations on an imcomplete vehicle, as that term is defined in Title 49 of the Code of Federal Regulations (CFR) Part 568.3, so that is becomes a completed vehicle, then Part 568, Vehicles manufactured in two or more stages, set forth the requirements you must meet. Under Part 568.6, Van Patton Vans, as the "final-stage manufacturer," would be required to complete the vehicle in such a manner that it conforms to all safety standards for buses in effect on a date no earlier than the manufacturing date of the incomplete vehicle, and no later than the date of completion of the final-stage manufacture. Also, your company must affix a label to the completed vehicle in accordance with the certification requirements set forth in Part 567,5, Requirements for manufacturers of vehicles manufactured in two or more stages. I have enclosed copies of 49 CFR Parts 567 and 568, for your convenience. I have also enclosed an information sheet that describes how you can obtain copies of NHTSA's regulations and motor vehicle safety standards. Please contact my office if you have further questions. Sincerely, Original Signed By Erika Z. Jones Chief Counsel Enclosures