Interpretation ID: nht81-2.32

DATE: 06/09/81

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Robinson L. P. Gas Company

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your recent letter requesting information regarding the conversion of school bus fuel systems to dual fuel carburetion running on propane gas. Specifically, you ask whether any regulations require that a protective cage be placed around a propane fuel tank, if propane carburetion is installed on a school bus.

The answer to your specific question is no. Federal motor vehicle safety standards and regulations do not require protective cages for propane fuel tanks. In fact, the Federal safety standard regarding fuel system integrity, Standard No. 301, is not directly applicable to propane fuel systems.

I am enclosing a fact sheet for your information which discusses the Federal implications of installing auxiliary fuel tanks and of converting fuel systems to use alternate fuels. From that fact sheet you will see that there may be certain responsibilities which must be met by persons converting school buses to use dual fuel systems. Please feel free to contact Hugh Oates of my staff if you have any further questions after reviewing this information (202-426-2992).

You will have to contact your State department of motor vehicles to determine if there are any local laws or regulations which would require the installation of a protective cage around propane fuel tanks.

SINCERELY

May 12, 1981

National Highway Traffic Safety Administration

Attn: Roger Tilton Legal Counsel

I recently had a conversation with Billie Renyolds, Executive Director of the National School Transportation Association and she directed me to your office for information regarding the conversion of school buses to dual fuel carburetion running on propane fuel.

More specifically, I am interested in finding if the application of a cage around a propane tank is necessary for installation of propane carburetion on school buses. There has been much controversy regarding this subject during the past year. Because Robinson L. P. Gas Company will be converting school buses to propane, we, of course, are very interested in knowing what the proper procedures should be according to state and federal codes.

As of this date, all propane conversions done in the state of Pennsylvania have not had a cage around the fuel tank. The tanks have been installed according to Pamphlet 58 and we are using ASME motot fuel 312 PSI tanks.

Thank you for your consideration. I will be looking forward to your reply in the near future.

Carol Kirk Marketing Representative

CC: RICHARD C. MARTIN -- ROBINSON L. P. GAS CO.