Interpretation ID: 000036drn

[ ]

Dear [ ] :

This responds to your request for an interpretation of Federal Motor Vehicle Safety Standard No. 217, Bus emergency exits and window retention and release. Specifically, you wish to know whether a front entrance door on the curb side of a non-school bus (over 10,000 pounds gross vehicle weight rating) may count towards the emergency exit requirement and can be credited the maximum allowable area of 3458 cm per exit. The answer is yes.

Before addressing the substantive question that you raised, I note that in a telephone conversation with Dorothy Nakama of my staff, you requested confidential treatment of the identity of your company. In order to save time, I agree to keep confidential the name of your company and all other identifying information in this letter. The enclosed copy of your redacted incoming letter will be placed in the public docket. We will make available to the public only the enclosed version of your letter to me that is purged of all references to your identity. [1]

You asked Ms. Nakama to address whether, for a non-school bus over 4,536 kg (10,000 lb) GVWR, Standard No. 217 permits manufacturers to designate the front entrance door as an emergency exit. If the door meets the standards emergency exit requirements, the answer is yes. We answered this question in the affirmative in a June 30, 1988, interpretation letter to Mr. Terry K. Brock of Coons Manufacturing Inc. (copy enclosed). In that letter, we stated that: "As long as the front door meets all applicable requirements for emergency exits under Standard No. 217, the door can be considered as an emergency exit. [I]t has never been this agencys position that only push-out window and roof exits may be used to satisfy Standard No. 217 requirements."

Standard No. 217 requirements for non-school bus emergency exits have been amended since the issuance of the interpretation letter to Coons Manufacturing. However, the agencys interpretation that a front door that meets Standard No. 217 emergency exit requirements can be considered an emergency exit has not changed.

I hope this information is helpful. If you have any further questions, please feel free to contact Dorothy Nakama at this address or at (202) 366-2992.

Sincerely,

Jacqueline Glassman
Chief Counsel

Enclosure
ref:212
d.5/8/03