Interpretation ID: nht89-2.92

TYPE: INTERPRETATION-NHTSA

DATE: AUGUST 31, 1989

FROM: CADWALLADER JONES -- PRESIDENT, JONES FORD INC.

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 3-20-90 TO CADWALLADER JONES, JONES FORD INC., FROM STEPHEN P. WOOD, NHTSA; [A35; VSA 102(14); PART 571.3]

TEXT: We need some help in the interpretation of Section 571.3 of Title 49 of the Code of Federal Regulations. This involves the sale, lease or rental of Ford Motor Company manufactured Econoline Vans and Club Wagons. We understand that these vehicles having more than 10 designated seating positions are not intended for use as "school buses" and are not designed to comply with certain Federal Motor vehicle safety standards uniquely applicable to school buses. We understand that a school bus is defined in S ection 571.3 as a "Motorvehicle -- designed for carrying more than 10 persons -- that is sold, or introduced into interstate commerce, for purposes that include carrying students to and from school or related events, but does not include a bus designed a nd sold for operation as a common carrier in urban transportation."

We have questions of further definition of "school bus" and of "student".

1. Is there an age limit or occupational definition of "student"?

A) Adults being transported to and from adult education classes by United Way.

B) College students-athletic teams, etc.

C) Churches that don't have day schools but transport children on occasions

D) Highschool students-athletic teams, etc.

E) Playground teams-no connection with schools

F) Day care center

We understand the prohibition against installing smaller size seats in a window van and painting it school bus yellow like we used to do in the '70s. It's these "fringe" uses that are not on a daily basis about which we are concerned.

We will appreciate your help in this area.