Interpretation ID: nht92-2.42

DATE: November 9, 1992

FROM: Rodney T. Nash -- Vice President Engineering, Collins Industries, Inc.

TO: Administrator, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 12/30/92 from Stephen P. Wood (signed by John Womack) (A40; Part 571.3)

TEXT:

Please forward this letter to the appropriate locations within the office of General Counsel to answer this question on vehicle designation. The final-stage manufacturer of a vehicle is required to label his vehicle with the information designated in FMVSS 115 and FMVSS 120. This information requires the final-stage manufacturer to designate the vehicle classification involved. We need to know how to classify an ambulance that is built on a truck chassis.

The ambulance carries more weight of specialized equipment for patient-care support than it carries people. The special purpose vehicles operates half of its life with no patient in the rear cargo area but always carries heart monitors, jaws of life, stretchers, respirators, and other life-support equipment. The question that needs clarification is what vehicle class (truck or MPV) should be applied to an ambulance. Should the classification change if the vehicle is focused on equipment transport over patient transport? It appears to us that the final-stage manufacturer is free to select between these categories.

Should you wish to discuss this question further, please call 316-663-5551 during normal working hours. I've taken the liberty of enclosing a piece of sales literature for a cargo intensive ambulance for you to review in issuing your opinion letter.

Thank you in advance for any prompt consideration you can give this request.