Interpretation ID: 20159.ztv

Ms. Tammy Ruff
Sandrail Mfg. Co.
231 E. Alessandro Blvd 344
Riverside, CA 92508-8963

Dear Ms Ruff:

The Federal Highway Administration has forwarded to us for reply your letter of May 5, 1999. Your letter has been supplemented with information obtained from a telephone call to your office on June 23, 1999, by the agency's Office of Vehicle Safety Compliance, as well as from your website on June 22, 1999.

You ask for a list of "the necessary equipment to enable the street legal construction of dune buggies to be driven in Hawaii" as rental vehicles.

Under the laws that we administer, a vehicle that is "street legal," i.e., which is manufactured primarily for use on the public roads, is required to comply with all applicable Federal motor vehicle safety standards. Your website information describes the Sandrail as "designed to be driven on soft sand, the beach and tall hills." Thus, the Sandrail has not been designed primarily for on road use and, in its present configuration, is not a "motor vehicle" subject to our jurisdiction.

However, your present intent is to construct "street legal" Sandrails. We shall consider those vehicles as manufactured primarily for use on the public roads and therefore "motor vehicles" which must comply with our laws regulating motor vehicles and their manufacturers.

Our Office of Vehicle Safety Compliance learned from your company on June 23, 1999, that the vehicles that Sandrail intends to manufacture will be capable of speeds of more than 25 miles per hour. The on-road Sandrail will be required to meet the same Federal motor vehicle safety standards as "multipurpose passenger vehicles" (assuming that the dune buggies retain their capability for occasional off-road operation). These standards include the requirements to provide air bags for the driver and outboard front seat passenger. Sandrail is also required to submit to this agency certain information relating to its VIN in accordance with 49 CFR Part 565 Vehicle Information Number.

Sandrail is also required, within 30 days after it commences manufacture of motor vehicles, to file with us an information statement in compliance with 49 CFR Part 566 Manufacturer Identification.

I enclose a copy of a "New Manufacturers" information package which will outline our requirements for manufacturers.

If you would like more information on the Federal motor vehicle safety standards, or have any other questions, please contact the agency's Office of Vehicle Safety Compliance.

Sincerely,
Frank Seales, Jr.
Chief Counsel
Enclosure
ref:500
d.7/22/99