Interpretation ID: aiam1166
Vice President-Engineering
Crown Coach Corporation
2500 East Twelfth Street
Los Angeles
CA 90021;
Dear Mr. Hartman: This is in reply to your letter of June 1, 1973, concerning Standar No. 217, Bus Window Retention and Release.' You raise two questions regarding the standard: the first concerns the incompatibility of the standard with buses designed to transport convicts or other persons under physical restraint, the second, the possibility that the standard may preclude the use of a push-button release mechanism for emergency exits which you apparently presently use in many buses you manufacture.; We have received other communications regarding the incompatibility o Standard No. 217 with buses designed to transport convicts and are presently considering requests that these buses be exempted from the standard.; With respect to the use of push-button emergency exit releas mechanisms, Standard No. 217 does not specify the design of the emergency exit release mechanisms but, rather, specifies requirements which these release mechanisms, regardless of design, are required to meet. These requirements essentially specify the magnitude and direction of release forces necessary to operate the emergency exit release mechanism. If these requirements do preclude the use of a push-button release mechanism you wish to use, the appropriate procedure for you to follow is to petition for rulemaking to amend the standard, in accordance with NHTSA regulations (49 CFR SS553.31 *et seq.*, copy enclosed). We recommend that you include detailed information on the type of release you wish to use as part of any such petition.; Yours truly, Richard B. Dyson, Assistant Chief Counsel