Interpretation ID: nht95-1.59

TYPE: INTERPRETATION-NHTSA

DATE: February 11, 1995

FROM: Richard Kreutziger -- EXEC DIR. NYSBDA

TO: Walter Myers -- STAFF COUNSEL, NHTSA

TITLE: NONE

ATTACHMT: ATTACHED TO 4/26/95 LETTER FROM JOHN WOMACK TO RICHARD KREUTSIGER (A43; PART 565)

TEXT: MR. MYERS; I DID TRY TO REACH YOU BY PHONE ON FRIDAY (2/10/95) PERTAINING TO THE LONG STANDING QUESTION RELATING TO THE INTRUSION OF THE LEFT SIDE EMERGENCY DOOR ON A SCHOOL BUS OF THE FOLDING SEAT, UNDER PROVISIONS OF FMVSS 217 AMENDED, WHEN THERE IS VERY DISTINCT ILY DEPICTED A 30 CENTIMETER AISLE (CLEAR) EVEN THOUGH THERE IS FROM 1/4" TO 3/4" INTRUSION BY THE FOLD UP SEAT FRAME.

I WILL BE ATTENDING A MEETING MONDAY (2/13/95) AT WHICH I AM CONFIDENT THAT THIS QUESTION WILL ONCE AGAIN ARISE - AND I WOULD BE MOST GRATEFUL ESPECIALLY IN LIGHT OF ACTION ONE WAY OR THE OTHER FOR YOU TO CONTACT ME AT 607-722 - 7575

I AM NOT NOT TRYING TO PICK ON YOU BUT ANOTHER QUESTION HAS DEVELOPED WHICH IN MY RESEARCH OF THE CFR FOR TRANSPORTATION HAS NOT PROVIDED ME WITH MUCH OF AN ANSWER.

THE "QUESTION" PERTAINS TO "MODEL YEAR" DATING. I HAVE FOUND UNDER THE SECTION RELATING TO "VIN" THAT THE MODEL YEAR IS TO BE INCLUDED AT A SPECIFIED POINT - BUT MY DIRECT QUESTION - IS THERE ANY FEDERAL MANDATE STATUTE - REGULATION - LAW - THAT PROVIDE S A SPECIFIC DATE OR TIME FRAME IN WHICH A MANUFACTURER HAS TO CHANGE MODEL YEAR DATING - PROVIDING ESPECIALLY IF THERE IS NO CHANGE IN THE VEHICLE PRODUCTION MAKE-UP OR DESIGN FEATURE. I AM AWARE THAT MOST OF THE BIG THREE AUTO COMPANY'S MAKE ANNUAL CH ANGES, BUT THEY ARE ALWAYS ADDING OR DELTING A "WIDGET". ANY INFORMATION YOU MIGHT HAVE WOULD BE MOST APPRECIATED. THANK YOU.