Interpretation ID: 18260b.drn

Mr. Bob Douglas
Director of Product Integrity
AmTran Corporation
P. O. Box 6000
Conway, AR 72033

Dear Mr. Douglas:

This responds to your request for an interpretation whether your new school bus emergency exit door locking system (the "VANDAL-LOCK") meets S5.2.3.3 of Standard No. 217, "Bus Emergency Exits and Window Retention and Release," without the addition of a key device. I regret the delay in this response. As explained below, the answer is yes.

Your letter describes the VANDAL-LOCK as a locking system that consists of a "dead bolt, cover and ludwig snap bolted to the body, and a guide mounted to the door." The cover contains a switch that is activated if the dead bolt is moved to the locked position. Activation of the switch prevents the operation of the engine starting system. If the engine is not already operating, it cannot be started as long as the dead bolt is applied to the exit. If the engine is operating and the dead bolt is closed, a warning buzzer will sound at the driver's compartment. The ludwig snap is a device used to keep a bolt in place so that an open bolt does not inadvertently close and a closed bolt does not inadvertently open.

You state that some States want VANDAL-LOCK to be modified by replacing the ludwig snap with a key device, which would allow the driver to have control of the dead bolt's position, since the key would be the only means of operating the dead bolt. You believe that the VANDAL-LOCK system without the key device meets S5.2.3.3 of Standard No. 217 and wish NHTSA to confirm your position.

S5.2.3.3 of Standard No. 217 states:

The engine starting system of a bus shall not operate if any emergency exit is locked from either inside or outside the bus. For purposes of this requirement, "locked" means that the release mechanism cannot be activated and the exit opened by a person at the exit without a special device such as such as a key or special information such as a combination.

This section requires an engine interlock that prevents the engine from being started if any emergency exit is locked from inside or outside the bus. Your VANDAL-LOCK would prevent the starting of a vehicle as long as the door is in the locked position (i.e., the engine cannot be started as long as the dead bolt is applied to the exit). A school bus with such a system would meet S5.2.3.3 (assuming, of course, that the interlock system performs as required on the vehicle). That section does not require a specific means of unlocking a door, e.g., by means of a key.

As to whether Standard No. 217 prohibits a key-operated device, the answer is no. We have addressed "vandal locks" in previous interpretation letters. Our position has been that nothing in Standard No. 217 prohibits the installation of locking doors as long as the vehicle cannot be started with the emergency door in the locked position. I have enclosed copies of our December 17, 1982 letter to Mr. M.B. Mathieson and our November 27, 1990 letter to Mr. Cal Karl on this issue.

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

Sincerely,
Frank Seales, Jr.
Chief Counsel
Enclosures
ref:217#VSA
d.3/30/99