ID: 7913

Mrs. M. Frances Parton
5788 Cypress Cr.
Tallahassee, FL 32303

Dear Mrs. Parton:

This responds to your letter of October 7, 1992, requesting information on whether a 1992 van can be modified by installing swivel bases on the seats so that you can transfer from the seat to a wheelchair. It is unclear from your letter whether the seat you want modified is a front or a rear seat. As explained below, there is no federal requirement that expressly prohibits installing a swivel base on a seat, provided that the seats and belts continue to comply with the applicable safety standards.

Some background information on Federal motor vehicle safety laws and regulations may be helpful. Section 103 of the National Traffic and Motor Vehicle Safety Act (the Safety Act; 15 U.S.C. 1392) authorizes NHTSA to issue Federal Motor Vehicle Safety Standards for new motor vehicles and new items of motor vehicle equipment. Manufacturers are required to certify that their products meet all applicable safety standards.

Any manufacturer, distributor, dealer, or repair business that modifies a van for you along the lines described in your letter after you have purchased the van would be subject to the requirement of the Safety Act (at 15 U.S.C. 1397(a)(2)(A)) that:

No manufacturer, distributor, dealer, or motor vehicle repair business shall knowingly render inoperative, in whole or in part, any device or element of design installed on or in a motor vehicle . . . in compliance with an applicable Federal motor vehicle safety standard.

Since the seats and their safety belts are devices or elements of design installed in the van in compliance with applicable safety standards, this section prohibits any of the named commercial entities from making any modification or repair to the seats and/or their accompanying safety belts if such modification or repair would cause the vehicle no longer to comply with an applicable safety standard.

Adding a swivel base to a seat, and presumably moving the seat belts for the seat, could affect compliance with four safety standards: Standard No. 207, Seating Systems, Standard No. 208, Occupant Crash Protection, Standard No. 209, Seat Belt Assemblies, and Standard No. 210, Seat Belt Assembly Anchorages. Standard No. 207 establishes strength and other performance requirements for vehicle seats. Standard No. 208 sets forth requirements for occupant protection at the various seating positions in vehicles. Based upon the information in your letter, it appears that the vehicle you wish to have modified would be classified as a multipurpose passenger vehicle (MPV) for purposes of NHTSA's regulations. Standard No. 208 requires an MPV to provide occupant crash protection to belted front seat occupants when the vehicle is crash tested at 30 miles per hour (mph) into a concrete barrier. Standard No. 208 also requires an MPV to have a lap/shoulder belt at every rear outboard seating position, and either a lap belt or a lap/shoulder belt at every other rear seating position. Standard No. 209 sets forth strength, elongation, webbing width, durability, and other requirements for seat belt assemblies. Standard No. 210 establishes strength and location requirements for seat belt anchorages.

As you can see, with the exception discussed below, there is nothing in Federal law that prohibits persons from adding a swivel base to a seat. Instead, Federal law requires that modifications to a van that include adding a swivel base to a seat be done in such a way that the seats and safety belts continue to provide the safety protection mandated by the safety standards.

With respect to Standard No. 208's requirements for front seats, NHTSA has recently received a number of phone calls and letters, from van converters and individuals, suggesting that the crash testing requirement for front seats in MPVs will, in effect, prohibit van converters from modifying vehicles to accommodate the special needs of persons in wheelchairs. The agency has also received a petition from the Recreation Vehicle Industry Association (RVIA) requesting an amendment to the light truck and van crash test requirement "to eliminate requirements that inadvertently discriminate against individuals with disabilities including individuals who use wheelchairs."

On January 9, 1992, the agency granted the RVIA petition. On August 5, 1992, the agency issued a notice of proposed rulemaking (NPRM) to amend the requirements of Standard No. 208 to give manufacturers of certain light trucks and vans the option of installing non-dynamically tested manual safety belts instead of complying with the dynamic testing requirements. However, the agency is aware that you and others who need to purchase a new vehicle need more immediate relief than a rulemaking can offer. Therefore, as explained in the NPRM, the agency has stated that it will not conduct any dynamic testing under Standard No. 208 of vehicles modified for operation by persons with disabilities while this rulemaking is pending. If you need to have the swivel base added to a front seat, this should allow you to find a converter to make this modification while this decision is pending.

I hope you find this information helpful. If you have any other questions, please contact Mary Versailles of my staff at this address or by phone at (202) 366-2992.

Sincerely,

Paul Jackson Rice Chief Counsel

ref:207#208#209#210 d:11/25/92

ID: 7919

Mr. Wolfgang W. Klamp
8105 Chehalis Road
Blaine, Washington 98230

Dear Mr. Klamp:

This responds to your letter of October 28, 1992, with respect to problems encountered by your wife in her use of a 1992 Canadian Ford Tempo passenger car.

Your letter indicates that your wife works in Canada, and uses the Ford, a company car owned by her employer, to travel to and from her home in the United States. Because the vehicle is not certified as meeting the U.S. Federal motor vehicle safety standards, she has been informed by U.S. Customs officials at the border that it may not be admitted in the future without going through the formal entry process for conversion to the U.S. standards. You have asked for our consideration of this matter.

The National Traffic and Motor Vehicle Safety Act prohibits the importation into the United States of motor vehicles that do not conform, and that are not certified by their manufacturers to conform, to all applicable U.S. Federal motor vehicle safety standards. As a legal matter, each time the Ford crosses the border from British Columbia to Washington, it is being imported into this country. It has been the policy of this agency for many years to regard Canadian and Mexican-registered vehicles engaged in daily cross-border traffic as subject to the importation prohibitions of the Act, and to require their compliance with the U.S. Federal motor vehicle safety standards. This is the reason why your wife is encountering difficulties at the border.

We have several suggestions. If the Ford is equipped with automatic occupant protection such as an air bag or automatic belts, it may, in fact, comply with all the U.S. standards. If this is the case, then Ford of Canada may be willing to provide your wife with a letter certifying its compliance to the U.S. standards which she could present at the border. Customs should honor such a letter, and allow the vehicle to proceed with no further delay. If this is not the case, perhaps her employer could provide her with a Canadian- manufactured car that does meet, and is certified as meeting, the U.S. standards. Otherwise, your wife may have to use a U.S.-registered and certified vehicle and seek reimbursement for travel expenses from her Canadian employer.

Sincerely,

Paul Jackson Rice Chief Counsel ref:591 d:11/16/92

ID: 7922

Ms. Janet Taylor
Marketing and Sales Manager
A-PEX International Co., Ltd.
2900 Lakeside Drive
Suite 101
Santa Clara, CA 95054-2812

Dear Ms. Taylor:

This responds to your letter seeking information on how the laws and regulations administered by this agency would apply to a device called the "Tap Root Equipment Stand." The equipment stand consists of a base plate which is bolted to the floor of a vehicle, a vertical tube which attaches to the base plate, and a rotating shelf at the top of the tube. The stand is intended to be used for portable equipment such as laptop computers, facsimile machines, and car phones.

By way of background information, NHTSA does not provide approvals of motor vehicles or motor vehicle equipment. Under the National Traffic and Motor Vehicle Safety Act (Safety Act), it is the responsibility of the manufacturer to ensure that its motor vehicles or equipment comply with applicable Federal safety standards. The following represents our opinion based on the facts provided in your letter.

NHTSA does not have any safety standards specifically covering equipment stands. However, it is possible that the installation of an equipment stand could affect the compliance of a vehicle with some safety standards.

All new motor vehicles manufactured for sale in the United States must be certified by their manufacturers as complying with the applicable Federal motor vehicle safety standards. If an equipment stand is installed in a certified vehicle prior to its first sale to a customer, the person making the installation would be considered a vehicle alterer. Under our certification regulation (49 CFR Part 567), a vehicle alterer must certify that the vehicle as altered continues to comply with all applicable Federal motor vehicle safety standards. Manufacturers, distributors, dealers, or motor vehicle repair businesses modifying a used vehicle are prohibited by Section 108(a)(2)(A) of the Safety Act from knowingly rendering inoperative any safety device or element of design installed on or in a motor vehicle or item of motor vehicle equipment in compliance with an applicable Federal motor vehicle safety standard. Thus, if an equipment stand is installed in a used vehicle, any businesses making such installations cannot render inoperative the vehicle's compliance with any of our standards.

In order to determine how installation of the Tap Root Equipment Stand could affect the compliance of vehicles with applicable Federal safety standards, you should carefully review each standard, including but not limited to those addressing occupant crash protection and occupant protection in interior impact. In that regard, I am enclosing for your information a fact sheet entitled Information for New Manufacturers of Motor Vehicles and Motor Vehicle Equipment, and a booklet entitled Federal Motor Vehicle Safety Standards and Regulations.

By way of example, Standard No. 208, Occupant Crash Protection, requires, among other things, that passenger cars and multipurpose passenger vehicles and trucks with a GVWR of 8,500 pounds or less meet specified performance requirements in a crash test. In particular, test dummies occupying the front outboard seating positions must comply with specified injury criteria in a 30 miles per hour barrier crash test. The specified injury criteria are the head injury criteria (HIC), chest acceleration and deflection, and femur loading. Nothing in the testing requirements of Standard No. 208 explicitly prohibits the installation of an equipment stand in the interior of vehicles. However, the Tap Root Equipment Stand appears to have hard surfaces and sharp edges, especially as compared with the padded dashboard, steering wheel, seats, and other components the test dummy may contact in a crash. It may not be possible for a vehicle to satisfy the injury criteria during dynamic testing if the equipment stand was installed in an area contacted by the test dummy, or if the stand interfered with the deployment of air bags.

Individual vehicle owners may modify their own vehicles without being subject to the federal safety standards. If the equipment stand is to be installed by such individual owners, however, I urge them to take potential safety hazards, such as those previously listed, into account before attempting to install the equipment stand. Manufacturers of motor vehicles and motor vehicle equipment are also subject to the defect provisions of the National Traffic and Motor Vehicle Safety Act. If data indicated that a device such as an equipment stand exposed occupants to an unreasonable risk of injury, such as from sharp edges resulting in injuries during crashes, the agency might conduct a defect investigation which could lead to a safety recall.

I also note that, apart from the issue of whether the equipment stand itself posed any safety risk to vehicle occupants, it is possible that the means of installation could create problems. The manufacturer should ensure that the recommended means of installation would not result in such things as the seepage of vehicle exhaust gases into the passenger compartment or weakening of the metal floor pan.

I hope this information is helpful to you and your client. If you have any further questions or need some additional information, please feel free to contact David Elias of my staff at this address or by telephone at (202) 366-2992.

Sincerely,

Paul Jackson Rice Chief Counsel

Enclosure

ref:208 d.12/28/92

ID: 7923

Mr. J. Leslie Dobson
Owner
McKinney Vehicle Services
8400 East Slauson Avenue
Pico Rivera, CA 90660

Dear Mr. Dobson:

This responds to your letter dated October 27, 1992, in which you asked how your company would go about lowering the Gross Vehicle Weight Rating (GVWR) assigned to some "Bobtail" trucks. Your letter explained that your company is a truck rental company that owns about 50 Bobtail trucks with a GVWR of approximately 28,000 pounds each. According to your letter, your company's rental business has decreased dramatically since the State of California's requirement for a commercial driver's license to operate vehicles with a GVWR of greater than 26,000 pounds took effect. You would now like to lower the GVWR of your trucks to 26,000 pounds so that the trucks would no longer be subject to the commercial driver's licensing requirements.

In a March 19, 1991, letter to Mr. Jerry Tassan, the owner of a truck rental company in San Francisco, I explained that the only parties that can assign or modify a vehicle's GVWR are the vehicle's original manufacturer, a final stage manufacturer, or an alterer. In a July 1, 1992, letter to Mr. Gene Fouts, I explained that modifications to an assigned GVWR should be made only when the manufacturer had made an error regarding the originally assigned GVWR, not for reasons related to the GVWR threshold of the commercial driver's license program. I have enclosed copies of both these letters for your information. Accordingly, I do not believe there is any way whereby your leasing company could lower the GVWR assigned to your Bobtail trucks.

If you have any further questions about the subject of GVWR, please feel free to contact Steve Kratzke of my staff at this address or by telephone at (202) 366-2992.

Sincerely,

Paul Jackson Rice Chief Counsel

Enclosures ref:567 d:11/20/92

ID: 7930

Mr. Kenneth W. Webster II
Project Engineer
Transportation Research Center Inc.
East Liberty, OH 43319-0367

Dear Mr. Webster:

This responds to your letter of October 26, 1992, seeking an interpretation of Standard No. 124, Accelerator Control Systems (49 CFR 571.124). More specifically, your letter requested clarification of the correct test procedure for S5 of Standard No. 124 under a specific condition.

By way of background information, under the National Traffic and Motor Vehicle Safety Act, each manufacturer is responsible for certifying that its vehicles or products meet all applicable safety standards. Manufacturers must have some basis for their certification that a vehicle or product complies with all applicable safety standards. This does not necessarily mean that a manufacturer must conduct the specific tests set forth in an applicable standard. Certifications may be based on, among other things, engineering analyses, actual testing, and computer simulations.

Section S5 of Standard No. 124 requires vehicles to comply with certain requirements "when the engine is running under any load condition, and at any ambient temperature between -40 F. and +125 F. after 12 hours of conditioning at any temperature within that range." (Emphasis added.) For purposes of the safety standards, the term any "means generally the totality of the items or values, any one of which may be selected by the Administration for testing." (49 CFR 571.4) Therefore, vehicles must meet Standard No. 124's requirements at all temperatures within the specified range.

Your letter states that some vehicles are impossible to start after conditioning for 12 hours at -40 F. You asked which of the following procedures would be correct when testing a vehicle which will not start:

Alternative (1): Test with engine not running at the -40 F. test condition.

Alternative (2): Raise temperature until engine will start. Record test temperature and perform test.

In conducting a compliance test, NHTSA would follow the procedures set forth in Standard No. 124. The agency would not follow the Alternative (1) test procedure since the standard specifies requirements that must be met "when the engine is running."

The agency could conduct a compliance test at any temperature or temperatures within the specified -40 F. to +125 F. range. I note that S5.3 specifies that the performance requirement for maximum time to return to idle position varies depending on whether the vehicle is "exposed to ambient air at 0 F to -40 F. during the test or for any portion of the 12- hour conditioning period." This language makes it clear that the ambient air does not need to be held at a single temperature during the conditioning period or during the test.

If NHTSA chose to conduct a compliance test at -40 F. and the vehicle would not start because of the extreme cold, the agency would most likely either use a standard engine heater to assist in starting the vehicle or warm the entire vehicle to a temperature where it would start. I note, however, that if the agency did warm the vehicle to assist in starting, it might lower the temperature back down to -40 for purposes of conducting the test.

I hope you find this information helpful. If you have any other questions, please contact Mary Versailles of my staff at this address or by phone at (202) 366-2992.

Sincerely,

Paul Jackson Rice Chief Counsel

ref:124 d.12/24/92

ID: 7935

The Honorable Connie Mack
United States Senate
1342 Colonial Boulevard, Suite 27
Fort Myers, FL 33907

Dear Senator Mack:

Thank you for your letter of December 12, 1994, addressed to the Intergovernmental & Consumer Affairs office of this Department. You forwarded to us a letter from your constituent, Mr. Howard J. Levy, Vice- President, Used Tire International, of Deerfield Beach, Florida.

Mr. Levy expressed concern in his letters to you and this agency, the National Highway Traffic Safety Administration (NHTSA), about a proposed bill in the Puerto Rico Senate which would require that used tires imported into Puerto Rico have not less than 5/32 inch tread depth and which would impose a tax of $10 per tire on such imports. Mr. Levy is concerned that the proposed bill would mean the end of the used tire industry on the island. In his letter to this agency, he asked, "Does NHTSA have jurisdiction over these laws in Puerto Rico or does the Puerto Rican Senate control the regulations over highway safety," and requested our help in this matter.

We have carefully evaluated Mr. Levy's concerns. As discussed in our enclosed response to Mr. Levy, however, we have concluded that the laws and regulations that we administer will not be of help to him. Since our opinion is limited to consideration of the laws and regulations that we administer, we have suggested to Mr. Levy that he may wish to consult a private attorney concerning whether the proposed Puerto Rico bill raises other legal issues that are relevant to his concerns.

Sincerely,

Philip R. Recht Chief Counsel

Enclosure ref:109 d:1/17/95

ID: 7964

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Mr. Ron Noirfalise Director of Pupil Transportation Missouri Department of Elementary and Secondary Education Post Office Box 480 Jefferson City, MO 65102-0480

Dear Mr. Noirfalise:

This follows up your telephone conversation of November 10, 1992, with Walter Myers of my staff regarding a newly- effective statute in Missouri which revises state requirements on transportation of school children. You also stated that you were told by your counterpart in the State of Washington that Federal law prohibits transportation of school children in vehicles with a passenger capacity of less than ten people.

As discussed in your telephone conversation with Mr. Myers, I have enclosed four recent letters explaining Federal law and pertinent regulations applicable to school buses and transportation of school children. These four are a November 3, 1992 letter to Mr. G. Thomas Owens, a July 7, 1992 letter to Senator Jim Sasser, a May 27, 1992 letter to Mr. Gerald A. Guertain, and a January 15, 1991 letter to Ms. Carol C. Verenea. These letters cover a variety of issues that, I think, will clarify your understanding of the issues with which you are concerned. Also enclosed is a copy of a pamphlet issued by this agency entitled Federal Motor Vehicle Safety Standards and Regulations, revised June 1989, and an information sheet issued by this agency entitled Where to Obtain NHTSA's Safety Standards and Regulations.

In addition, I am enclosing for your information a copy of Highway Safety Program Guideline No. 17, Pupil Transportation Safety. This publication was issued under the authority of the Highway Safety Act of 1966 which authorizes this agency to issue nonbinding guidelines that states may refer to in developing their highway safety programs. Guideline 17 was jointly issued by this agency and the Federal Highway Administration to provide recommendations to the states on various operational aspects of their school bus and pupil transportation safety programs. Among other things, Guideline 17 recommends that any vehicle designed to carry more than ten persons which is used as a school bus comply with all safety standards applicable to school buses at the time the vehicle was manufactured.

I hope the enclosed information will be of assistance to you. If you have any further questions, feel free to contact Mr. Myers at this address or at (202) 366-1992.

Sincerely,

Paul Jackson Rice Chief Counsel

Enclosures

ref:571 d:11/20/92

ID: 7968

Mr. Mike Love
Manager, Compliance
Porsche Cars North America, Inc.
P. O. Box 30911
Reno, Nevada 89520-3911

Dear Mr. Love:

This responds to your request that NHTSA determine that a proposed modification to a previously approved antitheft device on the Porsche 911 car line constitutes a de minimis change to the device. The change is proposed to be made on only one model in the 911 line and to be effective beginning with the 1994 model year (MY). As explained below, the agency concludes that the proposed change to the antitheft device is not a de minimis change.

As you are aware, in a Federal Register notice of June 2, 1989 (54 FR 23727), NHTSA determined that the antitheft device, to be placed as standard equipment on the MY 1990 Porsche 911 car line, was likely to be as effective as parts marking. Subsequently, by letter dated May 31, 1990, the agency concluded that proposed changes to the antitheft device in the MY 1991 Porsche 911 car line were de minimis changes. The primary change for the 1991 model year was that the interior light control units were to be integrated with the alarm control unit and central locking system. The latter two components were already integrated.

For the following reasons, NHTSA concludes that the proposed change to the antitheft device for the 1994 model year is not de minimis. In reaching this conclusion, we looked primarily at the anti-theft system on which the exemption was originally based. Under the original system, locking one door would automatically lock all doors, as well as arm the alarm system. Under the proposed change, locking one door with the key would no longer automatically lock all doors, but would still arm the alarm system.

This is not an insignificant change like the substitution of new components for old components, each serving the same function. Nor does the change involve adding a feature making an exempted antitheft device even more effective. The change in question lessens the likelihood that all doors of a car will be locked, thus easing a thief's access to the passenger compartment. A thief may easily open the unlocked door, providing an opportunity to attempt to shut off the alarm system (since both the alarm control unit and the power lines from the battery to the alarm system are inside the vehicle) and to circumvent the engine disabling system. If the thief successfully overcomes these systems, theft of the entire vehicle or its parts is facilitated.

Once inside the vehicle, a thief may open the hood by a release in the vehicle interior, thereby gaining access to the storage space under the hood. Since the battery for the Porsche 911 is also located in the front hood compartment of the vehicle, access to the battery also makes it easier for a thief to attempt to shut off the alarm system and engine disabling system, again facilitating theft of the entire vehicle or its parts.

Because the same aspects of performance (i.e., the central door locking system that automatically locked all doors, making access to the vehicle interior and hood release more difficult), are not provided in the proposed device, resulting in the possibility of the vehicle's increased vulnerability to being stolen in whole, or to have its parts stolen, this agency concludes that Porsche's proposed modification to the antitheft device in one model in the MY 1994 911 car line is not a de minimis change.

If Porsche wishes to place its proposed antitheft device on the 911 car line, it must formally file a petition with NHTSA pursuant to 49 CFR 543.9(c)(2). Please note that the petition for a modification must provide the same information for the modified device as is required under 543.6 for a new device. This includes the statement in 543.6(a)(1) that the antitheft device will be installed as standard equipment on all cars in the line for which an exemption is sought.

Since the modification planned by Porsche would result in one model within the car line lacking a feature found on the anti- theft systems of other models, the agency would determine in the following manner whether the car line continued to merit exemption. It would regard the system of the one model as the system of the car line as a whole and assess whether that system would be as effective in preventing theft as parts marking. The additional feature on the other models within the car line, i.e., the central locking system, would be regarded as an addition to the standard equipment system and would not have any bearing upon the exemptability of the car line. NHTSA notes that this same approach would not be taken if the system to be installed on a single model within a car line could not be regarded as a stripped down version of the system on the other models. In that case, there would be no standard equipment version of the system and the car line would not be eligible for an exemption.

If you have any questions, please contact Ms. Barbara A. Gray, Chief, Motor Vehicle Theft Division, Office of Market Incentives, Office of Rulemaking, NHTSA, at this address or by telephone at (202) 366-1740.

Sincerely,

Barry Felrice Associate Administrator for Rulemaking

ref:543 d.12/1/92

ID: 7980

Mr. Richard Horian
President, Woodleaf Corp.
1458 West 240th Street
Harbor City, CA 90710-1393

Dear Mr. Horian:

This responds to your two letters of November 6, 1992, with respect to the allowability under Federal regulations of the "Sudden Brake Indicator Hazard Light." As you describe it, "when a driver engages in hard braking, a circuit activates a separate lighting system to warn other drivers to pay special attention to a potentially hazardous situation."

This system will not utilize any of the existing rear lights on a vehicle, and will consist of a single lamp or pair of lamps, either mounted separately, or in the same housing as the center high-mounted stop lamp. The system will be red or amber in color, and either steady burning or flashing. The system is activated only when a predetermined threshold of pressure is reached upon depression of the brake pedal.

Supplementary lighting systems such as the one you have described are permissible as original motor vehicle equipment under Federal Motor Vehicle Safety Standard No. 108 Lamps, Reflective Devices, and Associated Equipment if they do not impair the effectiveness of the lighting systems required by the standard, or if there is no provision of the standard that affects them. Paragraph S5.4 of Standard No. 108 specifically prohibits the physical combination of the center highmounted stop lamp with any other lamp or reflective device, thus your system could not be used in a common housing with the center light (see copy of enclosed letter to Mr. S. Suzuki on this subject). However, if the system is mounted separately, under the circumstances you have presented, we do not believe that there would be any direct impairment of the required rear lights, or indirect impairment such as might be created when confusion may result upon simultaneous operation of the supplementary light and any required light.

As the letter to Mr. Suzuki indicates, passenger cars manufactured before September 1, 1985, were not required to be equipped with the center lamp. This means that your light could be combined in the same housing as a center lamp intended for installation on vehicles manufactured before September 1, 1985, but it could not be part of a replacement center lamp intended for use on vehicles manufactured subsequently. In addition, with the exception just noted, installation of the system on a vehicle in use would not appear to affect the safety functioning of any safety system necessary for continued conformance of the vehicle, it would appear that your system is acceptable for sale and installation in the aftermarket as well. However, the individual States have the authority to regulate lamps for vehicles in use, and we suggest that you contact the American Association of Motor Vehicle Administrators (AAMVA) for an opinion as to whether the system is permissible under State laws. AAMVA's address is 4600 Wilson Boulevard, Arlington, Va. 22203.

Sincerely,

Paul Jackson Rice Chief Counsel

Enclosusre ref:108 d.12/7/92

ID: 7981-2

Emmett Koelsch Coaches
ATTN: Kim Welsh
926 Delaware
Longview, WA 98632

Dear Sir/Madam:

Your letter of November 5, 1992 addressed to the Department of Transportation Publications Department was forwarded to this office for response. In your letter you requested a copy of the Federal motor vehicle safety standards pertaining to school buses "and other Transit type vehicles."

The Federal motor vehicle safety standards issued by this agency, the National Highway Traffic Safety Administration (NHTSA), apply to all classes and categories of motor vehicles, including passenger cars, trucks, buses of all types including school buses, multipurpose passenger vehicles, and the like. Excluded from the definition of motor vehicles are such vehicles as farm tractors, earth-moving equipment, and other off-road vehicles. For your information, I am enclosing a pamphlet issued by this agency entitled Federal Motor Vehicle Safety Standards and Regulations, which summarizes our safety standards. Also enclosed are copies of two fact sheets issued by this office entitled Information for New Manufacturers of Motor Vehicles and Motor Vehicle Equipment and Where to Obtain NHTSA's Safety Standards and Regulations.

You did not elaborate on what was meant by "Transit type vehicles." If you were referring to intercity buses, you should contact the Office of Motor Carrier Standards, Federal Highway Administration, Room 3404, this address for information on their pertinent standards and regulations. For information on intracity buses, you should contact the Federal Transit Administration, Room 9328, this address. Finally, for information regarding implementation of the Americans with Disabilities Act, you should contact the Office of Technical and Information Services, U.S. Architectural and Transportation Barriers Compliance Board, 1331 F Street N.W., Suite 1000, Washington, DC 20004-1111.

I hope this information is helpful. If after examining this material you have more specific questions, please feel free to contact Mr. Walter Myers of my staff at this address or by telephone at (202) 366-2992.

Sincerely,

Paul Jackson Rice Chief Counsel

Enclosures ref:571 d.12/10/92