Interpretation ID: aiam4023
Security and Legality Manager
Prevost Car Incorporated
Ste-Claire
Quebec
Canada
GOR 2VO;
Dear Mr. Turgeon: This responds to your August 12, 1985 letter to Administrator Stee regarding Federal Motor Vehicle Safety Standard (FMVSS) No. 217, *Bus Window Retention and Release*. Your letter has been referred to my office for reply. We apologize for the delay in our response.; Your questions concerned paragraph S5.3.2, which applies to buses othe than school buses. You asked whether the requirements of paragraph S5.3.2 may be met by: (1) release mechanisms located within the area defined by Figure 1 of the standard that are operated by a rotary or straight type of motion, and by (2) release mechanisms located within the area defined by Figure 2 operated by a straight type of motion.; Your understanding is correct. Rotary type motions may be used fo release mechanisms located in regions of low force application as shown in Figures 1 or 3 of the standard. Straight motions may be used for release mechanisms located in regions of low force application shown in Figures 1 and 3, and in regions of high force application shown in Figures 2 and 3.; Your second question asked whether the force application for a releas mechanism operated by a rotary motion is limited by S5.3.2 to 20 pounds. The answer is yes. Release mechanisms may be operated by a rotary type of motion in locations shown in Figure 1 or Figure 3 for low-force application. The magnitude of the force application must not be more than 20 pounds.; The second part of your question stated, 'In case of straight motion the force application is limited to 60 pounds.' This statement is not entirely correct. If the release mechanism is located in the low-force application areas shown in Figures 1 or 3, S5.3.2 specifies that the force applications must not exceed 20 pounds.; Your third question concerned the type of motions that are required t operate the release mechanisms. The first part of this question asked whether a rotary motion 'implies a rotation of the hand and twisting of the arm as for turning a door knob.' Standard No. 217 does not restrict you from using the particular type of rotary motion you described, provided that all other requirements of the standard can be met.; The second part of this question asked whether a straight motion mean 'a straight pull perpendicular to the emergency exit surface.' Paragraph S5.3.2(b) describes the direction of a straight high-force application as 'perpendicular to the undisturbed exit surface.' Your understanding, therefore, appears to be in accordance with S5.3.2.; The final part of this question asked whether 'a pull reasonabl perpendicular, i.e. at 70 degrees instead of 90 degrees, would be acceptable.' The answer to your question depends on whether one or two force applications are necessary to release the emergency exit. If only one force application is necessary, the direction of the application must meet the 90 to 180 degree directional requirement of S5.3.2. No variation from the requirements of the standard is permissible. However, paragraph S5.3.2 permits the use of two force applications for a single opening. Only one of the two force applications is required to differ by 90 to 180 degrees from the direction of the initial push-out motion of the emergency exit.; Your final question asked whether a particular type of push out windo in your buses would comply with FMVSS No. 217. As you know, this agency does not pass approval on the compliance of any motor vehicle or item of motor vehicle equipment with a safety standard before the actual events that underlie certification. Under the National Traffic and Motor Vehicle Safety Act of 1966, each manufacturer is required to determine whether its products comply with all applicable safety standards and regulations, and to certify its products in accordance with that determination. Therefore, the following only represents the agency's opinion based on the information provided in your letter.; You asked whether a push out window with a mechanism that can b released by a pull not exceeding 60 pounds in a direction opposite to the direction of the opening would meet the requirements of S5.3.2. The answer to your question depends on the location of the release mechanism. If it is located in the regions shown in Figures 1 or 3 for mechanisms released by low-force applications, the magnitude of the force application must not exceed 20 pounds. Release mechanisms located in regions of high force application must be capable of operation by force applications not more than 60 pounds. Of course, the other requirements in FMVSS No. 217 pertaining to emergency exits and release mechanisms must also be met.; I hope this information is helpful. Please contact this office if yo have further questions.; Sincerely, Erika Z. Jones, Chief Counsel