Interpretation ID: nht87-2.74

TYPE: INTERPRETATION-NHTSA

DATE: 08/20/87

FROM: TERRY K. BROCK -- COONS MANUFACTURING NATIONAL SALES MANAGER

TO: SEBASTIAN MESSINA -- NJ DEPT OF TRANSPORTATION CHIEF MOTOR CARRIER INSPECTIONS & INVESTIGATIONS

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 06/30/88 FROM ERIKA Z JONES TO TERRY K BROCK; REDBOOK A32, STANDARD 217; LETTER DATED 08/28/87 FROM ST MESSINA TO TERRY K BROCK RE COONS MANUFACTURING INC. DIAMOND VIP BUS 25 PASSENGERS MC 157-87; LETTER DATED 09/09/87 FROM TERRY K. BROCK. TO STEVE KRATZKE RE CLARIFICATION OF FMVSS CODE 217; OCC 1009

TEXT: Dear Mr. Messina,

I am writing regarding the 25 passenger Diamond VIP bus sold by Mr. Fred Sarlo of Wolfington Body Company. It was brought to our attention that we had not provided adequate emergency escapes per F.M.V.S.S. Code #217.

It was our pleasure to speak to your inspector, Mr. Vince LaBosio, yesterday via the telephone. He requested that I follow up our conversation with this letter to your attention.

It is very much a concern to Coons Manufacturing, Inc. that we are meeting the F.M.V.S.S. Code #217. However, we along with other manufacturers of this type bus, have in the past considered our front entrance door as an emergency side exit. We have enclosed diagrams of this electric entrance door. We are requesting you to better assist us in understanding why it is unacceptable to use this as one of the required side emergency exits. Also, on the driver's side we have, in the past, considered th e driver's window, which is 20"x20" clear opening or 400 square inches, as an additional side emergency exit. Again, it is our desire to meet the F.M.V.S.S. requirements, as well as, your own New Jersey requirements.

Please respond as soon as possible, in as much as, the customer has a very limited amount of time left on the 60 day extension permit that you extended to him. It is our desire to correct this problem prior to that permit expiring. Thank you for your assistance in this matter.

ENCLOSURE