Interpretation ID: 1983-1.43

TYPE: INTERPRETATION-NHTSA

DATE: 04/20/83

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Truck Body & Equipment Association

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your March 10, 1983, letter asking whether the requirement for audible alarms at school bus emergency doors applies only to emergency exit doors or to both doors and emergency exit windows.

Paragraph S5.3 of Standard No. 217, Bus Window Retention and Release, states specifically that the alarms shall be installed for emergency exit doors. There is no similar requirements for alarms at emergency window exits. Accordingly, alarm devices need be provided for emergency doors only.

SINCERELY, TRUCK BODY & EQUIPMENT ASSOCIATION

March 10, 1983

Office of Chief Counsel National Highway Traffic Safety Administration Attn: Roger Tilton

Dear Mr. Tilton:

This will confirm our telephone conversation of March 10th regarding FMVSS 217. One of TBEA's members would like a written interpretation of whether or not buses (not school buses) with a GVWR of more than 10,000 pounds require an audible alarm system for emergency exits, in this case push out windows so designated, other than doors.

The confusion is caused by S5.2.1 of FMVSS-217 which states in part -- "by providing side exits and at least one rear exit that conforms to S5.3 through S5.5". S5.3 specifically requires the audible alarm for emergency doors only. The standard clearly and consistantly delinates between emergency doors and emergency exits.

Is it reasonable to assume that on buses (not school) with a GVWR of more than 10,000 pounds that the audible warning system applies only to emergency doors and does not apply to emergency exits?

Your kind assistance in this matter will be appreciated.

James E. Forrester Manager, Engineering Services