Interpretation ID: 77-4.7

TYPE: INTERPRETATION-NHTSA

DATE: 09/28/77

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

TO: Thomas Built Buses, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your August 19, 1977, letter asking whether Standard 217, Bus Window Retention Release, allows the identification of the rear emergency door located anywhere on the top half of the door.

The standard in S5.5.3 requires the emergency door identification to be located "at the top of or directly above the emergency exit. . . ." The National Highway Traffic Safety Administration interprets this requirement to mean that the emergency door label must be located on the top half of the door or directly above the door. The label location as depicted in the picture you enclosed with your letter appears to comply with the requirements S5.5.3.

SINCERELY,

Thomas BUILT BUSES, INC.

August 19, 1977

Office of the Chief Counsel U.S. Department of Transportation

Attn: Roger Tilton, F.M.V.S.S. - 217

Enclosed is a photo showing the location of the wording "Emergency Door" on the rear of a school bus.

This is in reference to our phone conversations regarding Section S5.5.3. School Buses of 17 August, 1977. (F.M.V.S.S. - 217)

The glass area at the top will have an illuminated sign with the words "School Bus". When not used as a school bus by State Law it must be covered.

The result is that the cover does not permit the word "Emergency Door" to be on top of the door and, also, the size required by S5.5.3. Pennsylvania requires a three (3) (Illegible Word) letter which is impossible.

Actually, we feel that the location on a school bus as pictured is safer particularly in a vertical position since it is closer to a person eye level.

We trust you will look with favor upon this request, and wish to thank you for your courtesies to us during our phone conversations.

James Tydings, Specifications Engineer