Interpretation ID: 2521y

Mr. Ken Stone
Automotive Safety Engineering
Canewdon Consultants Group Limited
The Maltings, Locks Hill
South Street
Rochford, Essex SS4 1BB
England

Dear Mr. Stone:

This is in response to your telefax to Barry Felrice, Associate Administrator for Rulemaking, concerning the definition of a walk-in van. I apologize for the delay in responding to your inquiry.

You requested a definition of the term "walk-in van," particularly with regard to floor to roof height requirements, bulkhead requirements, step height requirements, and the presence of a front passenger seat. Although Federal Motor Vehicle Safety Standard No. 208 uses the term to describe a specific type of vehicle, neither that standard nor any other agency regulation defines the term. None has been necessary to date since the term is largely self-defining. For a vehicle to be regarded as meeting the term, it must be possible for a person to enter the occupant compartment in an upright position. Examples of walk-in vans include the GMC Step Van, and the large delivery vans used by the U.S Postal Service and the United Parcel Service in this country.

If you need further information concerning whether the vehicle you propose to import would be considered a walk-in van, I suggest that you provide this office with information concerning the configuration and dimensions of the vehicle. Photographs of its interior and exterior would be helpful as well.

I hope you have found this information useful.

Sincerely,

Paul Jackson Rice Chief Counsel /ref: VSA d:6/29/90