Interpretation ID: 77-1.43

TYPE: INTERPRETATION-NHTSA

DATE: 03/09/77

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Blue Bird Body Company

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your February 8, 1977, letter asking whether a New York state requirement mandating the installation of both side emergency doors and rear emergency doors in school buses would mean that both emergency doors would be required to comply with the school bus exit specifications in Standard No. 217, Bus Window Retention and Release.

The NHTSA has determined previously that only those exits required by S5.2.3 must meet the requirements specified for school bus emergency exits in Standard No. 217. Paragraph S5.2.3 requires either a rear emergency door or a side emergency door and a rear push out window. The side emergency door to which you refer is installed in addition to a rear emergency door. The presence of the rear emergency door, alone, satisfies the requirements of S5.2.3. Therefore, a side emergency door is not required by the standard and need not meet the specifications for school bus emergency exits. Emergency exits installed in school buses beyond those required in S5.2.3 must comply with regulations applicable to emergency exits in buses other than school buses. These requirements are also detailed in Standard No. 217.

SINCERELY,

BLUE BIRD BODY COMPANY

February 8, 1977

Frank Berndt Chief Counsel National Highway Traffic Safety Administration

SUBJECT: FMVSS 217

The latest New York state specifications require emergency doors as follow: Capacity Rear Emerg. LH Emerg. Door RH Emerg. Door Door Rear of Center Rear of Center 17-30 X 31-48 X X 49-66 X X 67 & up X X X

At a recent meeting of the New York State Bus Body Association we understand that it was stated: "The rear emergency door will be described in the future as a primary emergency exit and the side emergency door defined as a secondary exit. The only requirement for the secondary emergency door will be that the ellipsoid defined in Federal Specifications will pass through the side emergency door without obstruction."

Is this statement correct regarding a side emergency door when it is in addition to a rear emergency door (FMVSS 217 - S5.4.2.1(b))? This would allow the seat back in front of the side emergency door to extend into the door opening in this case.

Thanks for your help in this matter.

W. G. Milby Manager, Engineering Services