Interpretation ID: nht91-2.27

DATE: March 12, 1991

FROM: Rueben K. Brown -- Product Engineer, Crane Carrier Company

TO: Chief Counsel -- Office of Chief Counsel, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 3-29-91 from Paul Jackson Rice to Rueben K. Brown (A37; Std. 105)

TEXT:

I am employed as a product engineer with Crane Carrier and am currently involved in FMVSS 105 testing of our school bus chassis. I am unclear on the applicability of the spike stop requirement for school buses greater than 10,000 lb. GVWR. There appears to be some confusion in the industry on this subject. (I have previously spoken with Zack Fraser, of NHTSA, who referred me to your office for an expert opinion.)

Please provide an interpretation of FMVSS 105 regarding spike stops on school buses greater than 10,000 lb. GVWR.

You can reach me at the Bendix Automotive Proving Grounds, New Carlisle, Indiana 46552 (219-654-7400) for approximately the next 2-3 weeks. After that I can be reached at the address shown above for Crane Carrier.

Thanking you in advance for your cooperation in this matter.