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Interpretation ID: aiam3536

Mr. E. L. Anderson, Project Engineer, Transportation Products Inc., P.O. Box 329, Suffern, NY 10901; Mr. E. L. Anderson
Project Engineer
Transportation Products Inc.
P.O. Box 329
Suffern
NY 10901;

Dear Mr. Anderson: This responds to your February 18, 1982, letter asking for a interpretation of Standard No. 217, *Bus Window Retention and Release*. In particular, you question the requirement of section S5.3.3 which specifies that a continuous warning device shall sound when a school bus ignition is in the 'on' position and the release mechanism for an emergency door is not closed. You ask whether depressing the button on the outside of the door should activate the warning device.; The actual requirement of S5.3.3 states that the warning device must b audible when the *release mechanism* is not in the closed position. The release mechanism is that mechanism that keeps the door from opening. So, for example, if the outside button were depressed but the actual door latch did not open and the door would not itself open, it would not be necessary for the warning device to actuate. However, I assume that the outside button releases the latch which in turn allows the door to open. If this is the case, then at the moment that the latch is released, the warning device must be audible. If this did not occur, it would be possible that the door could be in an open position with the vehicle operating and without the knowledge of the occupants.; I hope that this resolves the question for you. Sincerely, Frank Berndt, Chief Counsel