Interpretation ID: 2454y
Vice President, Engineering
Hehr International, Inc.
3333 Casitas Ave
P.O. Box 39160
Los Angeles, CA 90039-0160
Dear Mr. Kroll:
This is in response to your request for an interpretation of S5.5.1 and S5.5.2 of Standard No. 217; Bus Window Retention and Release (49 CFR 571.217). More specifically, I understand your request to refer to buses that are not school buses and that have a gross vehicle weight rating of more than 10,000 pounds. For such buses, S5.5.1 of Standard No. 217 provides that: "... each emergency door shall have the designation 'Emergency Door' or 'Emergency Exit' ... followed by concise operating instructions describing each motion necessary to unlatch and open the exit, located within 6 inches of the release mechanism." S5.5.2 requires that emergency exit "markings" be visible to occupants in specified locations, under lighting and occupant visual acuity conditions set forth in S5.5.2.
You suggested that S5.5.1 requires only the operating instructions, and not the emergency exit designation, to be located within 6 inches of the release mechanism. Similarly, you suggested that the legibility requirements applicable to emergency exit "markings" per S5.5.2 refer only to the emergency exit designation, and not to the operating instructions for that emergency exit.
We disagree with your suggested interpretation. I have recently discussed NHTSA's official interpretation of these provisions in Standard No. 217 in a January 26, 1990 letter to Mr. John G. Sims. A copy of that letter is enclosed for your information.
Please contact David Greenburg of this office at (202) 366-2992 if you have any further questions or would like some additional information concerning this subject.
Sincerely,
Stephen P. Wood Acting Chief Counsel
Enclosure ref:2l7 d:5/l8/90