Interpretation ID: aiam3032
Thomas Built Buses
Inc.
1408 Courtesy Road
P.O. Box 2450
High Point
NC 27261;
Dear Mr. Tydings: This responds to your May 21, 1979, letter confirming your discussion with Roger Tilton of my staff relating to the emergency exit requirements of school buses that are constructed with an additional exit door. The additional door is installed so that the vehicle can be better used as a general transit vehicle when not in use for school purposes.; The statements that you make in your letter are, for the most part accurate. However, your third statement which indicates that the additional door could not be marked as an emergency exit is not entirely accurate. Additional emergency exits in school buses, beyond those required by Standard No. 217, *Bus Window Retention and Release*, must comply with the emergency exit requirements applicable to exits in non-school buses. If the door to which you refer is not designed or constructed as an emergency exit but rather is designed as an additional door for the routine loading and unloading of passengers, it need not be labeled as an emergency exit. If on the other hand the door is intended as an emergency exit and is constructed in accordance with the emergency exit requirements for doors in non-school buses, it should be labeled as an emergency exit in accordance with the labeling requirements for exits in non-school buses.; Sincerely, Frank Berndt, Chief Counsel