Interpretation ID: aiam2373
Manager
Vehicle Safety Activities
Sheller-Glove Corporation
Vehicle Planning and Development Center
3555 St. Johns Avenue
Lima
OH 45804;
Dear Mr. Semark: This responds to Sheller-Globe's July 7, 1976, request for revision o the requirements of S5.4.2.1 of Standard No. 217 *Bus Window Retention and Release*, so that passage of the described parallelepiped through the emergency door can be effected with its lower surface several inches above the bus floor. Section 5.4.2.1 requires that the 45-inch dimension of the parallelepiped remain vertical, that the 24-inch dimension remain parallel to the opening, and that the lower surface remain in contact with the floor of the bus at all times.; The three specifications for passage of the parallelepiped through th opening are intended to describe, for the benefit of the manufacturer, how the NHTSA will conduct its compliance testing. These specifications do not represent a requirement that the opening be constructed without a threshold or corner obstructions. As the agency interprets this requirement, minor obstructions that do not necessitate passage of the parallelepiped through the opening more than 1 inch above the floor are not prohibited by this requirement. Thus, in the case you describe, the NHTSA would move the parallelepiped through the opening with its sides vertical and the rear surface parallel to the rear surface of the bus, just above the obstructions, but no more than 1 inch above the bus floor.; Sincerely, Frank A. Berndt, Acting Chief Counsel