Since the late 1980s, the National Highway Traffic Safety Administration has stored Interpretation Letters that that are particularly important in understanding the questions raised by school systems especially when they use vans to transport students that don't meet the federal laws and regulations that NHTSA administers. Before users look at any of these letters they should take a few minutes to read about Interpretation Files and why they are important?
Listen to what NHTSA says about the subject: "NHTSA's Chief Counsel interprets the statutes that the agency administers and the regulations that it promulgates. The Chief Counsel's interpretations, issued in the form of letters responding to questions from the motor vehicle industry and the public, represent the definitive view of the agency on the questions addressed and may be relied upon by the regulated industry and members of the public. These interpretations have always been available to the public in the agency's technical reference library. The World Wide web enables (NHTSA) to make them available through the Internet."
The Interpretations Database File is a collection of three databases contining Interpretation Letters issued by the agency's Chief Counsel. The first is the Chief Counsel's database consisting of all Interpretation Letters issued since January 1988 when NHTSA first began storing information in an electronic format. In addition, General Motors Corporation and the Association of International Automobile Manufacturers have made their files available for Interpretation Letters issued prior to 1988.
There are several hundred Interpretation Letters found on the NHTSA site that speak to the subject of vans in school service as well as school bus construction. NHTSA issues a word of caution about these interpretations. According to the agency: "In attempting to use these interpretations to resolve a question, please be aware that they represent the views of the Chief Counsel based on the facts of the individual cases at the time the letter was written. Further, interpretations that are relevant to your situation may not be available on the web site. Consequently, if you are aware of a previous interpretation that appears to address your question, please cite that interpretation and present your question to the Chief Counsel. Do not assume that the interpretation applies to your situation. Critical factual differences may exist between your situation and those addressed in previous interpretations. Further, the Agency's standards and regulations change from year to year, and past interpretations may no longer be applicable."
Written requests for additional interpretations should be addressed to:
The Chief Counsel
National Highway Traffic Safety Administration, NCC-01
400 7th Street, SW
Washington, D.C. 20590