Interpretation ID: aiam2341
Safety Engineering Specialist
ROHR Industries
Inc.
Post Office Box 878
Chula Vista
CA 92012;
Dear Mr. Ratz: This responds to Rohr Industries' April 27, 1976, letter asking how t test an emergency exit that contains no glazing in conformity with the provision of Standard No. 217, *Bus Window Retention and Release*, that specifies testing before and after a window retention test (S5.3.2). You also ask whether the emergency exit identification requirements of S5.5.1 specify the placement of operating instructions at a designated seating position which does not qualify as an adjacent seat' under the definition found in S4 of the standard.; The window retention requirement is not required in the case of a emergency exit that contains no glazing. Because this requirement is clearly inapplicable to such an exit, the emergency exit release requirements of S5.3.2 must be met, but without the need to conduct a window retention test.; In answer to your second question, S5.5.1 requires that a labe indicating the location of the nearest exit release mechanism be placed at adjacent seats' to any exit whose release mechanism is not located within the occupant space of that adjacent seat. There are no labeling requirements in S5.5.1 for seating that is not adjacent' to the exit. As you note, some interior configurations result in seating whose occupant space' is not within 10 inches of any emergency exit (measured as set forth in S4). Such seating would not have to be labeled with the location of the nearest release mechanism, although some manufacturers do provide this information voluntarily. The agency has evaluated a requirement for this labeling but considers present labelling practices adequate at this time.; Sincerely, Frank Berndt, Acting Chief Counsel