Interpretation ID: 1982-2.6

DATE: 04/19/82

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: M.A.N. Truck & Bus Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your October 1, 1981, letter asking whether it would be permissible to attach a label to a door stating "To Open Door In Emergency Pull Down". You indicate that the door is not an emergency door in compliance with Standard No. 217, Bus Window Retention and Release. You question whether the addition of the label in conformance to a contract with the Chicago Transit Authority (CTA) would make the door an emergency door that would be required to comply with the standard. The CTA requires that door to be so labelled because it desires the door to be used as a means of escape.

The standard states that buses shall be equipped with a minimum number of emergency exits and that all emergency exits shall be labelled properly and comply with the requirements of the standard. One purpose of the standard is to provide sufficient emergency exits. Another purpose is to provide uniform emergency exit markings and operating instructions. You have stated that your vehicle has the requisite number of emergency exits, properly marked, so that the door in question is not required in counting the total number of exits for purposes of complying with the standard.

As you know, not all doors are required to be emergency exits. For example, the front entrance door of a vehicle need not be an emergency exit. If it is not labelled an emergency exit, it need not comply with the requirements of the standard relative to emergency exits. Similarly, the door to which you refer need not comply with the emergency exit requirements if it is not labelled as an emergency exit. However, since your proposed label refers to the emergency nature of the door, it appears to place the door within the category of an emergency exit that would be required to comply with the standard. The CTA intends the door to be used as an emergency exit and the label will indicate to riders that the door is suitable for such purposes. You may not, therefore, refer to the door as an emergency door unless the door complies with all of the requirements.

SINCERELY,

M.A.N. TRUCK & BUS CORPORATION

October 1, 1981

General Counsel National Highway Traffic Safety Administration Department of Transportation

Dear Sir:

I am writing today to ask for your interpretation of Federal Motor Vehicle Safety Standard 217 to the extent that it affects the language of an instructional decal that we intend to affix at the front and rear entrances of our new series of articulated transit buses.

As we understand it, FMVSS 217 is a standard whose intent is to prescribe the amount of emergency exit area to be provided on buses, the nature of the emergency exits to be provided, and the way in which such exits must be identified.

We further believe that the vehicles we are preparing to manufacture in the United States more than meet the requirements of the standard. That is, through a combined use of push-out side windows and escape roof hatches that function and are identified according to FMVSS 217, the escape area requirement is exceeded. Therefore, we believe that the main passenger doors are not also required as emergency exits to qualify the bus under the 217 standard.

However, the language of the specification describing the buses of our current contract with the Chicago Transit Authority demands that additional escape area be provided by the main entrances. Manual operation of the main doors is accomplished via a two-step procedure. First, an operator with a red ball handle, located overhead on the door engine compartment, is pulled to release the air pressure that keeps the door closed. Second, the door panels are pushed open by the passenger. (For a better idea of the conditions at the entrances, please refer to the enclosed sketch.)

CTA further requires that this manual operation of the main doors be described in the following way by an instructional decal that is placed in close proximity to the red-handled operator:

TO OPEN DOOR IN EMERGENCY PULL DOWN.

It is the language of this decal that concerns us. Specifically, though the bus easily exceeds requirements of FMVSS 217, without the inclusion of the main doors as emergency exits, we are unsure that those doors could qualify as emergency exits under 217, and we therefore seek assurance from your office that the use of the word "emergency" in the decal does not violate the standard, as you interpret it.

We thank you in advance for your early response to this question.

Joseph R. Karner Project Engineer

cc: M. R. HOWARD; L. K. MIKALONIS; G. E. PICKETT; L. ROGERS; K. M. SIMON

NOTE: THIS IS A GENERAL CONFIGURATION SKETCH, NOT INTENDED TO ACCURATELY PORTRAY THE DOOR AREA.

(Graphics omitted)

SKETCH OF DOOR ARRANGEMENT M.A.N. TRUCK & BUS CORP. (CTA) DRAWN BY: J. R. KARNER 10-1-81