Interpretation ID: nht90-1.84

TYPE: Interpretation-NHTSA

DATE: March 23, 1990

FROM: Anthony H. Brett -- Womble Carlyle Sandridge & Rice

TO: Malcolm B. Mathieson -- Vice President - Engineering, Thomas Built Buses, Inc.

TITLE: Re Letter of August 8, 1989, from the Director of the Office of Motor Carrier Standards to the Executive Director of the National School Transportation Association

ATTACHMT: Attached to letter dated 12-3-90 from P.J. Rice from M.B. Mathieson (A36; Std. 217); Also attached to letter dated 3-26-90 from M.B. Mathieson to E.Z. Jones (OCC 4598); Also attached to letter dated 3-30-90 from M.B. Mathieson to M.F. Trentacos te; Also attached to letter dated 8-8-89 from M.F. Trentacoste to K. Finkel; Also attached to letter dated 9-29-77 from J.J. Levin, Jr. to M.B. Mathieson; Also attached to letter dated 7-5-84 from F. Berndt to R. Marion

TEXT:

This correspondence is in response to your letter of March 20, 1990, to Rod Ligon in our office. As I told you in our telephone conversation yesterday, you have correctly noted the error in the Federal Highway Administration's position concerning emerge ncy exits on school buses.

The letter to Ms. Finkel does not take into account the amendments which occurred in Standard 217 (49 C.F.R. S 571.217) to specifically address the emergency exit requirements of school buses. As you correctly noted in your letter, the predecessor of th e current Standard 217 did not distinguish between school and non-school buses. The application of the old standard to both categories of buses was problematic.

The revision of the standard established two separate categories of buses governed by different emergency exit requirements. Your responsibility as a manufacturer of school buses is to comply with the specific standard for school buses provided in S 5.2 .3.1.

Mr. Trentacoste's letter fails to take into account the revisions in Standard 217, which were adopted to address this very problem. If you have any questions, feel free to contact me at your convenience.