Interpretation ID: nht93-7.7

DATE: October 1, 1993 Est.

FROM: Bob Carver

TITLE: None

ATTACHMT: Attached to letter dated 11/22/93 from John Womack to Bob Carver (A41; Part 571; Std. 217)

TEXT:

I'm an engineer at Wayne Wheeled Vehicles, a commercial and school bus manufacturing company. My job here is to see ensure compliance to FMVSS 217, effective May 1994. I have a question for you in which I need an official ruling concerning FMVSS 217 S5.5.3(c):

Each opening for a required emergency exit shall be outlined around its outside perimeter with a minimum 3 centimeters wide retroreflective tape, either red, white, or yellow in color, that when tested under the conditions specified in S6.1 of 571.131 meets the criteria specified in Table 1.

If an emergency roof exit is required, is it necessary to outline it with the retroreflective tape even though it is not visible unless the bus is tilted on its side? Also, Charles Hott at NHTSA said that the width requirement will be revised to 1 inch. Can you confirm this?

Thanks in advance for your prompt consideration and assistance concerning this matter.