Interpretation ID: aiam3752
P. Eng.
Chief Engineer
Flyer Industries Limited
64 Hoka Street
Box 245 Transcona P.O.
Winnipeg
Manitoba
Canada R2C 3T4;
Dear Mr. Marcus: This responds to your letter to Mr. Kratzke of my staff, asking for clarification of the requirements of Standard No. 217, *Bus Window Retention and Release* (49 CFR S 571.217). You stated that your company's transit bus models use eight large windows as large as emergency exits to satisfy the emergency exit requirements of Standard No. 217, and that the entrance and exit doors are not classified as emergency doors. Accordingly, you stated that the entrance and exit doors do not 'have to be tested for Standard No. 217 requirements.' This is not wholly correct.; Standard No. 217 sets forth two basic requirements. These are (1 window retention requirements, which must be met by *all* windows in a new bus, except for the windshield, and (2) requirements applicable to emergency exits. As I pointed out in a letter to Mr. Moss, of your staff, the window retention requirements apply to all front door glazing which exceeds 8 inches in diameter, and this agency does test such glazing for compliance with the standard. Hence, while you may be correct in asserting that a door not designated as an emergency door would not be tested for compliance with the emergency exit requirements, you are incorrect if you are asserting that the glazing on such a door would not be tested for compliance with the window retention requirements.; Your letter went on to state that, although your entrance and exi doors are not classified as emergency exits, most local transit authorities have requested you to add a decal instructing people how to open the doors in case of an emergency. You then stated your opinion that the addition of these decals would not change the status of the doors to emergency exits, so the doors would not be required to meet the Standard No. 217 push force requirements applicable to emergency doors. This conclusion is incorrect.; Standard No. 217 specifies minimum criteria for emergency exits whic must be met by all new buses, and your letter states that your transit bus models do not need to count the entrance and exit doors on the buses to satisfy these criteria. Thus, absent other factors, those doors would not be required to comply with the portions of the standard applicable to emergency doors. However, affixing a decal, such as the one enclosed with your letter, in the area of those doors is labeling the door as an emergency exit. It is reasonable for riders of the bus to assume that a door which is labeled by the manufacturer with instructions in case of an emergency and which is intended by the local transit authority to be used as an exit in case of an emergency is in fact a door which can be used as an emergency exit. Given the likelihood of the use of the door as an emergency exit when it is so labeled, it is important that the door comply with the requirements applicable to emergency doors in Standard No. 217, and this agency has uniformly required this of all doors labeled with instructions for use in case of an emergency.; For your information, I have enclosed a copy of a letter reaching thi same conclusion which was sent to another manufacturer. Contrary to the understanding expressed in your letter, this agency has never sent a letter to a manufacturer stating that doors labeled with emergency instructions were not subject to the requirements of Standard No. 217 applicable to emergency doors.; Should you need any further information or have further questions o this subject, please contact Mr. Kratzke at this address or at (202) 426-2992.; Sincerely, Frank Berndt, Chief Counsel