Interpretation ID: nht80-3.35

DATE: 08/06/80

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Mr. Nick Oliver

TITLE: FMVSR INTERPRETATION

TEXT: This confirms your July 25, 1980, conversation with Roger Tilton of my staff concerning your plans to rehabilitate school buses.

As you stated, your initial program of bus rehabilitation appears only cosmetic in nature. You will do some maintenance work on the vehicles and repaint and letter them. Your only responsibility in this type of operation is not knowingly to render inoperative the compliance of the bus with any Federal motor vehicle safety standard. The type of operations that you would be performing are not likely to render inoperative any safety standard of which we are aware.

Your long-term plans are to make more substantial modifications of school buses. As Mr. Tilton said, if you install a new chassis on a used body it is the same as manufacturing a new motor vehicle. You would be required to comply with all of the new safety standards applicable to school buses. This would be very difficult when you use a bus body manufactured prior to April 1, 1977. That was the date of the applicability of the new school bus safety standards, and it would be almost impossible to upgrade an old bus body to comply with the new safety standards. You indicated that you do not plan this type of operation.

You stated that you might place a new chassis on bodies manufactured after April 1, 1977, if the original chassis were damaged in an accident. You still would be considered as the manufacturer of a new motor vehicle and would be required to certify that the vehicle complies with all of the applicable safety standards. However, it should be possible for you to mount a post-April 1, 1977, body on a new chassis and make the vehicle comply with all applicable standards.

If you have any further questions after receiving this information and after obtaining a copy of the Federal safety standards, please contact us.