Interpretation ID: nht90-3.49

TYPE: Interpretation-NHTSA

DATE: August 2, 1990

FROM: Oscar W. Harrell, Jr. -- Deputy Assistant Commissioner, Facilities Management, The Commonwealth of Massachusetts, Executive Office of Human Services, Department of Mental Retardation

TO: Office of the Chief Counsel, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 7-25-90 from George C. Shifflett to Oscar W. Harell (Harrell) Jr.; Also attached to letter dated 9-4-86 from Erika Z. Jones to Vincent Foster; Also attached to letter dated 11-26-79 from Frank Berndt to W.G. Milby; Also attached to letter dated 1-4-91 from Paul J. Rice to Richard Cahalan (A37; Part 567); Also attached to 49 CFR Chapter V (10-1-89 Edition) Part 567 (text omitted.)

TEXT:

During the past year I have had various contacts with Mr. George C. Shifflett, Safety Compliance Specialist, Office of Vehicle Safety about our concerns for the safety of our residents and staff accompanying them in the vehicles. The vendor who sold the vehicles to the state has converted the vehicles to accommodate the needs of the residents. When contacted last year the vendor stated that the vehicles, after being converted, comply with state and federal regulations.

While Mr. Shifflett and I have communicated about this at different times and I have received copies of two letters sent to persons addressing similar concerns, I have not received any regulations or rules answering our concerns as outlined and presented to Mr. Shifflett. Therefore, since we are committed to insuring the safety and welfare of our residents and staff, your interpretation of the aforementioned process and its applicability to us will be greatly appreciated.

I would like to take this opportunity in advance to thank you for your attention to this important matter.