Interpretation ID: nht90-1.8

TYPE: Interpretation-NHTSA

DATE: January 8, 1990

FROM: Ron Marion -- Sales Engineer, Thomas Built Buses, Inc.

TO: Cal Karl -- Commercial Vehicle Section

TITLE: None

ATTACHMT: Attached to memo dated 11-28-8? from C. Karl to All School Bus LCR II's; Also attached to letter dated 11-27-90 from P.J. Rice to C. Karl (A36; Std. 217); Also attached to letter dated 12-7-82 from F. Berndt to M.B. Mathieson; Also attached to letter dated 1-29-90 from C. Karl to M. Shaw (OCC 4403); Also attached to letter dated 1-18-90 from R. E. Meadows

TEXT:

This letter is in response to the Department of Public Safety memo recently printed in the January MSBOA newsletter.

As a bus body manufacturer we offer "Vandalocks" on both the emergency door(s) and service door of our products.

The service door Vandalock is a key activated handle located on the front of the vehicle. When the service door is closed the safety catch holds the door closed. The door cannot be opened from outside the vehicle. The front Vandalock allows the door t o be opened from outside by the use of a cam which releases the safety catch. Please note - the standard entrance door without a Vandalock cannot be opened from outside if the safety catch is engaged.

This front Vandalock is not connected to the ignition interlock for several reasons:

1. Federal standards only require the emergency doors (as listed in S5.2.3.1.) to be equipped with the interlock.

2. The door is only locked from the outside; not from the inside. Anyone can get out the door from the inside even if the Vandalock is in the locked position.

For this reasoning we feel we comply with Rule 3520.5010 subparagraph 2 for the front door because we are in compliance with FMVSS 217.

The Thomas Vandalock for emergency doors utilizes a "slide bolt" lock located on the inside of the door which is connected to an ignition interlock. The bus may not be started with the door "locked". The door may be locked once the bus is started; howe ver, a continuous buzzer will sound if the door is locked while the bus is running, thereby notifying the driver of a problem. This slide bolt type lock is equipped with a spring which requires a positive force to engage. This feature will not allow th e lock to become engaged by vibration or during rollover.

Thomas Built Buses has been using this type of Vandalock for at least 15 years (if not longer) without any problems. We feel we are in compliance

with the FMVSS 217 for the following reasons:

S5.2.3.2. "The engine starting System of a school bus shall not operate if any emergency exit is locked from either inside or outside the bus."

Our Vandalock has the ignition interlock and locks the door from inside the bus.

For purposes of this requirement "locked" means that the release mechanism cannot be activated by a person at the door without a special device such as a key or special information such as a combination."

It has been our interpretation that the words "such as" indicate an example, a key is not required but a "special device" or a combination is not required, but "special information."

As I have interpreted this article in the newsletter, the State of Minnesota will require buses with Vandalocks to only be locked from the outside and/or inside with a key or combination. At this time I am not aware of a Vandalock on emergency doors whi ch meets these requirements.

Vandalocks, as you are aware, are not necessary for the safe operation of school buses. They are provided at the customer's request to deter vandalism when the vehicles are parked.

There probably are numerous school buses in Minnesota which are equipped with Vandalocks which do not meet the 7/1/89 regulations which are now going to be required to be removed at the customer's expense.

We at Thomas Built Buses would like for you to reconsider the 7/1/89 regulation to allow our present Vandalock system to be acceptable.

Should you have any questions, please do not hesitate to contact me.