Interpretation ID: nht87-2.90

TYPE: INTERPRETATION-NHTSA

DATE: 09/09/87

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

TO: STEVE KRATZKE -- OFFICE OF CHIEF COUNCIL NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION

TITLE: CLARIFICATION OF FMVSS CODE #217

ATTACHMT: ATTACHED TO LETTER DATED 06/30/88 FROM ERIKA Z JONES TO TERRY K. BROCK; REDBOOK A32, STANDARD 217; LETTER DATED 08/20/87 FROM TERRY K BROCK TO SEBASTIAN MESSINA; LETTER DATED 08/28/87 FROM ST MESSINA TO TERRY K BROCK RE COONS MANUFACTURING INC. DIAMOND VIP BUS 25 PASSENGERS MC 157-87

TEXT: Dear Mr. Kratzke,

Pursuant to our telephone conversation regarding Coons Manufacturing, Inc.'s desire to provide adequate emergency escapes per FMVSS Code #217 in our Diamond VIP mini buses, I write.

Mr. S. T. Messina, Chief Motor Carrier Inspections and Investigations of the State of New Jersey, Department of Transportation has denied certification for a 25 passenger bus recently delivered to the State of New Jersey. Please refer to the attached letter dated August 28, 1987.

It is very much a concern to Coons Manufacturing, Inc. that we are meeting the FMVSS Code #217. However, we along with other manufacturers of this type bus, have in the past considered our front entrance door, which is labeled and equipped with the p roper emergency release mechanisms per the above referenced regulation, as an emergency side exit. Please refer to the attached sample materials of two competitors. We have enclosed diagrams of this electric entrance door as well as photos for your ref erence. We are requesting you to better assist us in understanding why this is unacceptable to use as one of the required side emergency exits. Also, on the driver's side we have in the past, considered the driver's window which is 20" x 20" clear open ing or 400 square inches as an additional emergency side exit.

Please respond as soon as possible as to whether or not our existing emergency exits provide adequate escape per FMVSS Code #217. If they do not, please state what would be required in addition to what we are already providing. It is our desire to c ooperate to the fullest regarding this matter. Thank you for your assistance.

ENCLOSURE