Interpretation ID: nht79-4.10

DATE: 03/13/79

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Blue Bird Body Company

TITLE: FMVSR INTERPRETATION

TEXT: This responds to your February 1, 1979, letter asking whether any law or regulation prohibits the remanufacture of a school bus with an old chassis and a new body when the completed vehicle does not comply with the new safety standards.

As you are aware, the agency has stated many times that such a remanufactured vehicle need only comply with the standards in effect on the date of manufacture of the chassis as long as the remanufacturing process conforms to the guidelines established in Part 571.7(e) of our regulations. The agency does not view the remanufacturing problem as significant, because a vehicle's chassis normally wears out before its body. The recycling of noncomplying buses will cease when the supply of used chassis manufactured prior to April 1, 1977, disappears.

SINCERELY,

BLUE BIRD BODY COMPANY

February 1, 1979

Joseph J. Levin, Jr. Chief Counsel National Highway Traffic Safety Administration

Dear Mr. Levin:

The intent of Public Law 93-492, Motor Vehicle and School Bus Safety Amendments of 1974, and the subsequent regulations resulting from that law was to upgrade the safety of the national school bus fleet.

We have recently become aware of an industry which seems to be designed to circumvent the intent of public law 93-492. The industry (see enclosure) is involved in the restoration and remanufacture of complete school buses including body and chassis.

We are aware of the agency's recent interpretation regarding the manufacture of bodies stating that the bodies must meet the safety standards that were in effect on the date of manufacture of the chassis.

However, we feel that this new industry could indefinitely recycle old buses into the fleet which do not meet the congressionally mandated safety standards for school buses.

In our opinion, we feel that this is a flagrant violation of the intent of the law. Therefore, we would like to ask you if there are any regulations or laws which would prohibit this practice.

Thank you for your early reply.

W. G. Milby Manager, Engineering Services

School Bus Restoration Co.

511 SO. LINCOLN STREET ELKHORN. WISCONSIN 53121 (414) 723-4309

PRICE LIST

EFFECTIVE AUGUST 1, 1978

School Bus Standard Type Forward Engine Cowl Mounted Specification 105

All body types, all lengths up thru 66 pass - Chevrolet Chassis $ 8950 *

All body types, all lengths up thru 66 pass - Ford Chassis $ 9250 *

All body types, all lengths up thru 66 pass - International Chassis $ 9250 *

All body types, all lengths up thru 66 pass - Dodge Chassis $ 8950 *

All body types, all lengths up thru 66 pass - G.M.C. Chassis $ 8950 *

Busses equipped with power steering additional 32500 *

* All Prices Plus Factory Rebult. Or New Engines. (Your Option)

Busses equipped with automatic transmission. Special Quote

School Bus Body Only

All body types, all lengths 48 thru 66 pass - Any Chassis 580000

Add-On eight light warning system 400

Please Add 20000 for each additional row of seats - Bus size over 66 pass. Restoration of internally mounted front engine and rear engine busses - will be on Special Quotation.

Any bus bearing unusual wear or damage will be on Special Quotation. All work performed is Guaranteed for 6 months or 6,000 miles. Guarantees on tires and batteries will be limited to mfg. Guarantee.

Engines are Guaranteed by the engine manufacturer in accordance with their individual policy and not by SCHOOL BUS RESTORATION. Or it's contract manufacturers.

All prices are subject to change without notice.