Interpretation ID: nht76-2.8

DATE: 10/07/76

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Truck Body and Equipment Association, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of August 24, 1976, in which you ask whether emergency exits required by a State beyond those required by Standard No. 217, Bus Window Retention and Release, are subject to the performance requirements outlined in S4(b) of Standard No. 220, School Bus Rollover Protection.

Standard No. 220 requires that all emergency exits provided in accordance with Standard No. 217 must meet certain minimum performance levels during and after the simulated rollover test. Additional emergency exits mandated by State law are not exits "provided in accordance with Standard No. 217" and, therefore, would not be subject to the requirements of S4(b) of Standard No. 220.

You should note that Standard No. 217, in addition to mandating the provision of certain school bus doors and exits under S5.2, also regulates certain aspects of all emergency exits under other provisions of the regulation.

SINCERELY,

TRUCK BODY AND EQUIPMENT ASSOCIATION, INC.

August 24, 1976

Frank Berndt, Acting Chief Counsel National Highway Traffic Safety Administration

FMVSS 220 "School Bus Rollover Protection" scheduled to become effective on April 1, 1977 will require the operation of each emergency exit during and after the simulated rollover test. This requirement is cited in FMVSS 220, S4 Requirements (b) and reads as follows:

"(b) Each emergency exit of the vehicle provided in accordance with Standard No. 217 (@ 571.217) shall be capable of opening as specified in that standard during the full application of the force, and after release of the force. A particular vehicle (i.e., test specimen) need not meet the emergency exit opening requirement after release of force if it is subjected to the emergency exit opening requirements during the full application of the force."

The State of New York has also issued regulations governing school buses bought in for use in that state (see NY 721.36 K and Z enclosed).

In order for a school bus manufacturer to comply with New York's specifications the bus must be built with roof hatches in addition to standard emergency exits as provided in FMVSS 217.

Our question is as follows:

Will additional emergency exits specified by a state over and above those required in FMVSS 217 be subjected to the performance requirements found in FMVSS 220 S4 (b)?

THANKING YOU IN ADVANCE.

Byron A. Crampton Manager of Engineering Services

ENC.

[New York Regulations Omitted.]