Interpretation ID: aiam0592
Truck Body & Equipment Association
Inc.
5530 Wisconsin Avenue
Suite 1220
Washington
DC 20015;
Dear Berkley: This is in response to the petition for rulemaking that you filed o behalf of manufacturers of ambulances and funeral coaches, requesting that they be given relief from some of the motor vehicle safety standards applicable to passenger cars, either by reclassification or otherwise.; You have pointed out the difficulties that ambulance and funeral coac manufacturers face in meeting the Exterior Protection standard, in light of the heavy weight of the vehicles and the necessary alterations of their rear ends for functional purposes. You noted that the Roof Crush Resistance standard will be difficult to meet because of the functional roof configuration of these vehicles, and that other passenger-car standards may cause similar problems in the future.; You also described the ways in which the chassis of these vehicles ar generally strengthened to bear their weight and perform their functions. The result of these alterations is such that these chassis, although they are produced by passenger car divisions of automobile manufacturers, are not passenger car chassis in the usual sense of the word.; A 'multipurpose passenger vehicle' is described in 49 CFR S 571.3 as ' motor vehicle with motive power, except a trailer, designed to carry 10 persons or less which is constructed either on a truck chassis or with special features for occasional off-road operation.' It has been determined that the policy considerations that led to the placing of vehicles with truck chassis into a category separate from passenger cars apply equally to ambulances and funeral coaches, and that the chassis used for these vehicles may reasonably be considered truck chassis for the purposes of this classification.; Please be advised, therefore, that the NHTSA will consider vehicle designed and manufactured for use as ambulances or funeral coaches to be multipurpose passenger vehicles, as defined in, and with respect to the application of, the motor vehicle safety standards and regulations.; Sincerely, Douglas W. Toms, Administrator