Interpretation ID: nht94-8.5

DATE: February 22, 1994

FROM: Robin L. Fennimore, Spectrum Engineering Group

TO: Office of Chief Council, NHTSA

TITLE: School Bus Safety Standards Our File: 94057

ATTACHMT: Attached to letter dated 6/28/94 from John Womack to Spectrum Engineering Group (A42; STD 206; FMVSS 217)

TEXT: We are currently reconstructing a motor vehicle accident involving a 16-passenger, mini school bus. As a result of this investigation, several questions have risen concerning design modifications performed on the right front entrance door of the vehicle; specifically, whether they are controlled by and in compliance with any and all applicable FMVSS. We would appreciate your assistance in resolving these concerns.

A 1988 Ford Econoline Cargo Van was purchased as an incomplete vehicle and later fitted with a school bus body by Midbus of Lima, Ohio. A copy of the van's I.D. plate and a Mid Bus brochure is enclosed for your reference. This vehicle was outfitted with a remote door opening/closing apparatus and latching mechanism, although maintained the original Ford van door. The O.E.M Ford latch/hinge mechanism was disabled by removing the striker plate.

On January 13, 1989, the operator of the bus lost control of the vehicle, striking both a tree and a utility pole. The collision allegedly caused the operator to be ejected from the vehicle through the right front passenger door.

Given this information, would you please respond to the following questions:

1) Would this vehicle be classified as a "multi-purpose passenger vehicle", a "bus" or a "school bus"?

5

2) Does FMVSS 206 and/or FMVSS 217 apply to the right front entrance door of this vehicle?

3) Which FMVSS would apply to the right front entrance door, (particularly its loading requirements)? Can you provide copies of the versions of these documents effective in 1988?

4) Can you please provide copies of the 1988 FMVSS 206 and 217?

If you have any questions or concerns, please do not hesitate to contact me at (203) 272-1111.

If there are any fees associated with this request, we will be happy to reimburse your office.