Interpretation ID: 77-4.10

TYPE: INTERPRETATION-NHTSA

DATE: 09/29/77

FROM: AUTHOR UNAVAILABLE; J. J. Levin, Jr.; NHTSA

TO: The Coachette Company

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your August 19, 1977, letter asking whether Standard No. 217, Bus Window Retention and Release, permits the use of two rear doors for the determination of the size of the required unobstructed rear exit opening.

The standard states in S5.4.2.2 that: "[a] school bus with a GVWR of 10,000 pounds or less shall conform to all the provisions of S5.4.2, except that the parallelepiped dimension for the opening of the rear emergency door or doors shall be . . . ." This section specifically allows the determination of the required rear opening through the use of either one or two doors. Therefore, your interpretation that the standard permits the use of two rear doors is correct.

SINCERELY,

Coachette Company

August 19, 1977

Joseph Levin Office of Chief Council N.H.T.S.A.

RE: FMVSS 217

We urgently need a clarification on FMVSS 217, paragraph S5.4.2. and specifically sub-paragraph S5.4.2.2., as these and other referenced sections apply to a van type school bus rear emergency exit.

The school bus in question had two rear emergency doors side by side with the left hand (driver's side) door hinged on the left side and the right hand door hinged on the right side. The operation of these doors require the right hand door to be opened first, then the left hand door may be opened. However, with just the right hand door open, there are couple of minor protusions into the opening that prevent the parallelepiped from passing through.

The two doors have very simple labels and instructions for operating would be clear and concise. (See enclosed sketch.)

Is our interputation correct that we would be in full compliance with FMVSS 217 if both doors were utilized to obtain the required unobstructed opening?

An early reply is desired and anything that can be done to expedite this clarification will be greatly appreciated.

E.M. Ryan Design Engineer

ENC.

ward

SCHOOL BUS MFG., Inc. P.O. BOX 311 HIGHWAY 65 CONWAY, ARKANSAS 72832

DATE - 8-19-77 CHK - DRAFT: 40M ENGR: SCALE IN OR OUT PART ORDER NO. REV CHANGE BY DATE

MATERIAL-

TOLERANCE

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