Interpretation ID: 18142.drn

Mr. Terry E. Quinn
Corporate Director of Marketing
Hehr International Inc.
3333 Casitas Avenue
Post Office Box 39160
Los Angeles, CA 90039-0160

Dear Mr. Quinn:

This responds to your request for an interpretation whether the release mechanism on your emergency exit windows for non-school buses meets S5.3.2 of Standard No. 217 Bus emergency exits and window retention and release. I regret the delay in this response. Because each window would have two release mechanisms that would each require more than the one "force application" per mechanism specified in S5.3.2, the answer is no.

S5.3.2 states in part:

When tested under the conditions of S6 both before and after the window retention test required by S5.1, each emergency exit not required by S5.2.3 shall allow manual release of the exit by a single occupant using force applications each of which conforms, at the option of the manufacturer, either to S5.3.2(a) or (b) of this section. Each exit shall have not more than two release mechanisms. . . . In the case of exits with two release mechanisms, each mechanism shall require one force application to release the exit.

Your letter describes a new feature that you have added to an existing window design. The feature is a retaining pin with a pull ring, on the release mechanism. The retaining pin fits through holes in the release mechanism's handle and its housing. With the new feature, the emergency exit window would now open as follows: "Pull the retaining pin upward or inward toward the center of the window; rotate emergency handles as before; push window outward." You informed Mr. James Jones of the National Highway Traffic Safety Administration's Office of Safety Assurance that each emergency exit window would have two release mechanisms.

We would consider each release mechanism to be opened by more than one "force application" because pulling the release pin alone would not open the window. Your window is designed such that for each release mechanism, at least one other force would have to be applied before the window is opened. Because at least two forces must be involved (per mechanism) before the emergency exit window can be opened, the mechanism does not meet S5.3.2's requirement that: "In the case of exits with two release mechanisms, each mechanism shall require one force application to release the exit."

I hope this information is helpful. You have any further questions, please feel free to contact Dorothy Nakama of my staff at this address or by telephone at (202) 366-2992.

Sincerely,
Frank Seales, Jr.
Chief Counsel
ref.217
d.8/11/99