Interpretation ID: 17175.drn
Mr. Vincent P. Schulze, Chief
Commercial Bus Inspection and Investigation
Motor Vehicle Services
New Jersey Department of Transportation
CN 160
Trenton, NJ 08666
Ref: MC#26-98
Dear Mr. Schulze:
This responds to your request for an interpretation whether under Federal Motor Vehicle Safety Standard No. 217, Bus emergency exits and window retention and release, bus(1) emergency exit windows may be designated with international symbols and have operating instructions labeled with international symbols instead of English instructions. You state that a bus manufacturer, Motor Coach Industries (MCI), "presented four buses in New Jersey for inspection using international symbols in lieu of English language on the emergency exit window." You provide no description or other information about the "international symbols."
Standard 217 includes S5.5, Emergency exit identification, which specifies in S5.5.1 that each emergency exit door shall have the designation "Emergency Door" or "Emergency Exit," and every other emergency exit shall have the designation "Emergency Exit," followed by "concise operating instructions describing each motion necessary to unlatch and open the exit, located within 16 centimeters of the release mechanism." Examples of operating instructions are provided in S5.5.1, as follows: (1) Lift to Unlatch, Push to Open; and (2) Lift Handle and Push out to Open.
With regard to designating the exits, S5.5.1 is explicit with regard to how emergency exit doors or other types of emergency exits must be designated. "[E]ach emergency exit door shall have the designation 'Emergency Door' or 'Emergency Exit,' and every other emergency exit shall have the designation 'Emergency Exit'. . . ." Use of the quotations in S5.5.1 indicates that the exact words "Emergency Door" or "Emergency Exit" are what are required to designate these emergency exits. We are unable to conclude by interpretation alone that a symbol is commensurate with the quoted language. Thus, a symbol cannot be provided in lieu of the words.
With regard to the operating instructions, S5.5 does not set forth explicit language that must be used to provide the required operating instructions (unlike the provision relating to the designation of an exit), nor does it otherwise expressly prohibit the use of symbols to provide the required information. However, the section requires that "concise operating instructions describing each motion necessary to unlatch and open the exit" must be provided. Since we do not know what the international symbols look like, we are unable to provide an opinion at this time as to whether the symbols at issue are explicit enough to instruct a frightened passenger how to open the emergency exit. Our Safety Assurance office will be contacting your office to obtain further information to help the agency decide whether to commence an enforcement proceeding regarding a possible noncompliance with Standard 217.
If you have any questions, please contact Paul Atelsek of my staff at (202) 366-2992.
Sincerely,
Frank Seales, Jr.
Chief Counsel
ref:217
d.6/22/98
1. For purposes of your inquiry, I will assume that you ask about buses other than school buses, and thus the sections in Standard 217 that apply to non-school buses are the relevant requirements.