Interpretation ID: 1983-1.38

TYPE: INTERPRETATION-NHTSA

DATE: 04/05/83

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Flyer Industries Limited

TITLE: FMVSS INTERPRETATION

TEXT:

APR 5 1983 NOA-30

W. E. J. Moss, P. Eng. Flyer Industries Limited 64 Hoka Street Box 245 Transcona P.O. Winnipeg, Manitoba Canada R2C 3T4

Dear Mr. Moss:

This responds to your January 27, 1983, letter asking about the application of Standard No. 217, Bus Window Retention and Release, to the front entrance doors of buses. You ask that the window retention test not be applied to your bus, because application of the required amount of force will cause the door to open. You state further that if the door had no glazing, it would not be tested for retention and, therefore, would be acceptable under the standard.

Standard No. 217 states that all glazing that exceeds 8 inches in diameter shall be tested for retention. During that test, neither the glazing nor the surrounding frame shall open in a manner that would allow a 4-inch sphere to pass through the opening. The intent of this requirement is of course to prevent the ejection of occupants in accidents.

The agency does test the front door of buses for compliance with this section if they contain glazing that meets the size requirement. In tests that have been conducted, most front doors have complied. Accordingly, the proper construction of front doors in compliance with the requirement would not appear to be a problem. The agency does not believe that it would be in the interest of safety to exempt front door glazing from the test requirements. Although passengers are required to stand behind the standee line as you note in your letter, they may easily be thrown forward of that line in an accident. The agency considers it important to reduce the possibility of their being thrown from the vehicle if such a situation were to arise.

You are technically correct that an all metal door would not be tested for compliance with this retention provision since it would not contain glazing. However, the agency would not view favorably the installation of doors in buses that open so easily in an accident. Use of such doors might be considered to be a safety-related defect subject to the agency's recall and remedy authority.

Sincerely,

Frank Berndt Chief Counsel

January 27, 1983

Administrator, National Highway Traffic Safety Administration, Attn: Mr. R. Tildon 400 Seventh Street S.W., Washington, D.C. 20590 U.S.A.

Petition

Dear Sir:

I wish a clarification of FMVSS #217 on the front doors of a transit coach. This coach has two piece "slide glide" type doors.

If a solid aluminum door is used and tested to FMVSS 217 the door will deflect enough to permit passage of the 4" ball. In this case the door will pass FMVSS 217, as there is no glazing in the door.

In the case of glazing in the door, "this is necessary to allow the driver visability", the deflection will be the same magnitude as a solid door permitting the passage of a 4" diameter ball. This then does not pass the FMVSS test on this glazing, as the frame is not retained by its surrounding structure, nor can it be.

I ask for an exception for the front door glazing of a transit coach from FMVSS 217. This would not pose a danger as the passengers are asked to stand behind a whiter yellow line on the floor rearward of the front door area.

Yours truly,

W.E.J. Moss, P. Eng Test Engineer

/jc B-286