Interpretation ID: nht87-3.40

TYPE: INTERPRETATION-NHTSA

DATE: DECEMBER 9, 1987

FROM: ROBERT CUZZI -- BREDA TRANSPORTATION, INC.

TO: ERIKA Z. JONES -- CHIEF COUNSEL, NHTSA

TITLE: 020-1287

ATTACHMT: MEMO DATED 6-17-88, FROM ERIKA Z. JONES, TO ROBERT CUZZI, STD 301

TEXT: My company, Breda Transportation, Inc., is currently working on a contract for the design, manufacture, and delivery of 236 articulated buses to the city of Seattle. the buses will be designed and manufactured in Italy, with final assembly in the United States.

The buses' fuel tank will be built in Italy, and my question regards this. I need to know what federal standards and regulations, if any, refer to the fuel tank. Yesterday, 12/8/87, I spoke to Ms. Deidre Hom of your office, and she informed me that FMV SS 301 applies to fuel tanks, but for vehicles with a GVWR of 10,000 pounds or less. There are, it seems, no applicable FMVSS standards.

Could you please confirm this, in writing, or advise me if there are any applicable federal standards which pertain to bus fuel tanks?

Your assistance is greatly appreciated.