Interpretation ID: 20944.drn
Monsieur Jean-Yves Le Bouthillier
Standards Manager
Les Entreprises Michel Corbeil Inc.
304, 12th Avenue
Laurentides, Quebec J JOR 1C0
CANADA
Dear Monsieur Le Bouthillier:
This responds to your request for an interpretation of whether, in describing tests for school bus emergency exit doors, Standard No. 217, Bus emergency exits and window retention and release, specifies use of a parallelepiped 45 inches high, 22 inches wide and 6 inches deep for school buses that are 10,000 pounds or less gross vehicle weight rating (GVWR) and for school buses that are 12,000 pounds GVWR. As explained below, a parallelepiped of that size is specified for testing the first type of school buses and not the second type.
Standard No. 217 specifies at S5.4.2.2, School buses with a GVWR of 10,000 pounds or less, that a school bus with a GVWR of 10,000 pounds or less "shall conform to all provisions of S5.4.2, except that the parallelepiped dimension for the opening of the rear emergency door or doors shall be 45 inches high, 22 inches wide, and six inches deep." Thus, a school bus with a GVWR of 10,000 pounds or less must have a rear emergency door or doors permitting unobstructed passage of a parallelepiped that is 45 inches by 22 inches by 6 inches.
Since it is "more than 10,000 pounds," a school bus with a GVWR of 12,000 pounds would be subject to S5.4.2.1 School buses with a GVWR of more than 10,000 pounds:
(a) ... each emergency exit door of a school bus shall ... be manually extendable by a single person to a position that permits:
(1) In the case of a rear emergency exit door, an opening large enough to permit unobstructed passage of a rectangular parallelepiped 114 centimeters high, 61 centimeters wide, and 30 centimeters deep.
In English measurements, the parallelepiped specified in S5.4.2.1(a)(1) is approximately 45 inches high by 24 inches wide by 12 inches deep. Thus, the parallelepiped specified for use in testing school buses of 12,000 pounds GVWR is wider and deeper than that specified for use in testing school buses with a GVWR of 10,000 pounds or less.
I hope this information is helpful. If you have any further questions, please feel free to contact Dorothy Nakama of my staff at this address or at (202) 366-2992.
Sincerely,
Frank Seales, Jr.
Chief Counsel
ref:217
d.3/15/2000