Interpretation ID: aiam3736
Federal Compliance Engineer
Champion Home Builders Co.
Dryden
MI 48428;
Dear Mr. Sims: This responds to your letter to Mr. Kratzke of my staff, concerning th emergency exit requirements of Safety Standard No. 217, *Bus window retention and release*, that apply to a 22 passenger bus with a gross vehicle weight rating in excess of 10,000 pounds. You indicated that your company counts the area provided by side doors in determining the total emergency exit openings for these buses. However, a state regulatory agency has advised you that side doors may not be used in computing the total emergency exit area required by S5.2 of Standard No. 217. Your letter stated that the state regulatory agency believes that the emergency exit opening for side exits must be provided by windows. The state regulatory agency is incorrectly interpreting the requirements of Standard No. 217 if they hold the position you have stated.; Section S5.2 of Standard No. 217 specifies requirements for th provision of emergency exits for buses, and S5.2.1 sets forth more specific requirements for buses with a gross vehicle weight rating of more than 10,000 pounds. As long as side doors meet all requirements applicable to emergency doors in Standard No. 217, they can be considered emergency exits for purposes of compliance with that standard. The agency has stated this position in several past interpretations, and has never indicated that only window emergency exits could be considered as side exits for purposes of compliance with section S5.2.1.; Should you have any further questions or need further information i this area, please contact Mr. Kratzke at this address, or by telephone at (202) 426-2992.; Sincerely, Frank Berndt, Chief Counsel