Interpretation ID: nht87-2.55

TYPE: INTERPRETATION-NHTSA

DATE: JULY 21, 1987

FROM: JAY COSTA -- ASSISTANT PROCUREMENT SPECIALIST, METROPOLITAN SEATTLE

TO: DEIKA Z. JONES -- CHIEF COUNSEL, NHTSA

TITLE: NONE

ATTACHMT: MEMO DATED 2-23-88, TO JAY COSTA, FROM ERIKA Z. JONES, STD 271, REDBOOK A31; MEMO DATED 6-18-87, CONTRACT NO. T/F 19-84 REAR EMERGENCY WINDOW; MEMO DATED 6-25-87, CONTACT NO. T/F 19-83 REAR EMERGENCY WINDOW

TEXT: We have a unique problem with our articulated trolley coach which we believe you may be able to help us solve.

The problem we are experiencing concerns passengers opening the rear emergency window and pulling the ropes, causing the poles to dewire. This could cause serious injury to the passenger doing this as well as to others. It is also an interruption of se rvice, as the driver must stop the bus and put the poles back on the wire. It is our belief that in the interest of safety the rear emergency window should be removed and replaced with a non-operable type window. This task can be done quite simply by o ur Body Shop.

As we understand FMVSS 217, we could accomplish this task. We inquired of the manufacturer of the trolley about this problem and enclose copies of their letters on this topic. Their letters also include information on the available emergency windows an d hatches on this bus. These 46 buses are 60 ft. long, three-axle articulated buses which are electrically powered from overhead wires.

We would like to receive from you clarification on FMVSS 217 and a formal opinion regarding our proposed action.

ENCLOSURES