Interpretation ID: aiam2523

Mr. W.G. Milby, Manager, Engineering Services, Blue Bird Body Company, P.O. Box 937, Fort Valley, GA 31030; Mr. W.G. Milby
Manager
Engineering Services
Blue Bird Body Company
P.O. Box 937
Fort Valley
GA 31030;

Dear Mr. Milby: This responds to your February 8, 1977, letter asking whether a Ne York state requirement mandating the installation of both side emergency doors and rear emergency doors in school buses would mean that both emergency doors would be required to comply with the school bus exit specifications in Standard No. 217, *Bus Window Retention and Release*.; The NHTSA has determined previously that only those exits required b S5.2.3 must meet the requirement specified for school bus emergency exits in Standard No. 217. Paragraph S5.2.3 requires either a rear emergency door or a side emergency door and a rear push out window. The side emergency door to which you refer is installed in addition to a rear emergency door. The presence of the rear emergency door, alone, satisfies the requirements of S5.2.3. Therefore, a side emergency door is not required by the standard and need not meet the specifications for school bus emergency exits. Emergency exits installed in school buses beyond those required in S5.2.3 must comply with regulations applicable to emergency exits in buses other than school buses. These requirements are also detailed in Standard No. 217.; Sincerely, Frank A. Berndt, Acting Chief Counsel