Interpretation ID: nht74-3.27

DATE: 09/23/74

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Toyota Motor Sales Inc.

TITLE: TITLE: FMVSR INTERPRETATION

TEXT: This is in response to your letter of August 12, 1974, inquiring as to whether or not a vehicle with unitized construction, developed as a truck and converted to carry passengers may be classified as a multipurpose passenger vehicle.

Your description of the vehicle in question indicates that it does qualify as a multipurpose passenger vehicle. The reference to "truck chassis" in the MPV definition was intended to include vehicles that were designed and developed as trucks but have been produced in a version for carrying passengers. Since the delivery van referenced in your letter was developed as a truck, its modification to enable the carrying of passengers places it in the MPV category.

TOYOTA MOTOR SALES, U.S.A. INC.

August 12, 1974

James B. Gregory Administrator National Highway Traffic Safety Administration

We would like to request your interpretation of "multipurpose passenger vehicle" as defined in @ 571.3 Definitions of PART 571-FMVSS Subpart A.

Our concern is with the meaning of "truck chassis" and whether or not we can classify the following vehicle in the MPV category under the above-cited definition.

Among our car lines we have a delivery van, a diagram of which is attached. This van has a unitized body construction, but it was developed for cargo transportation. In other words, it could be classified as a truck. If we were to install enough seats in this van to enable it to carry ten passengers or less, could this vehicle as modified be classified in the MPV category?

Your interpretation of the above will be greatly appreciated.

THANK YOU.

K. Nakajima

Director/General Manager

Factory Representative Office

ATTACHMENT (Graphics omitted)

(Graphics omitted)

Wheelbase: 2200 mm