Interpretation ID: 77-4.20

TYPE: INTERPRETATION-NHTSA

DATE: 10/17/77

FROM: AUTHOR UNAVAILABLE; J. J. Levin, Jr.; NHTSA

TO: Thomas Built Buses, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your August 31, 1977, letter asking whether a New York state requirement mandating the installation of both side emergency doors and rear emergency doors in school buses would mean that both emergency doors would be required to comply with the school bus exit specifications in Standard No. 217, Bus Window Retention and Release.

The NHTSA has determined previously that only those exists required by S5.2.3 must meet the requirements specified for school bus emergency exists in Standard No. 217. Paragraph S5.2.3 requires either a rear emergency door or a side emergency door and a rear push out window. The side emergency door to which you refer is installed in addition to a rear emergency door. The presence of the rear emergency door, alone, satisfies the requirements of S5.2.3. Therefore, a side emergency door is not required by the standard and need not meet the specifications for school bus emergency exists. Emergency exits installed in school buses beyond those required in S5.2.3 must comply with regulations applicable to emergency exists in buses other than school buses. These requirements are also detailed in Standard No. 217.

SINCERELY,

Thomas BUILT BUSES, INC.

August 31, 1977

Office of the Chief Counsel U.S. Department of Transportation

Attn: Roger Tilton Subject: FMVSS - 217, Specific to Emergency Doors - Relating to New York State School Bus Regulations - New York State Department of Transportation.

We respectfully request a decision of the legality of the seat placement in the case of side emergency door(s) as noted in S5.4.2.1(b), when you also have a rear emergency door that complies with S5.2.3.1.

Our request speaks only to school buses, and vehicles of 10,000 pounds or greater. New York State required the following emergency doors. Passengers Doors Location 17-30 1 Rear Center 31-48 2 (1) Rear Center (1) Left Side 49-66 2 Same as 31-48 67 or more 3 (1) Rear Center (1) Left Side (1) Right Side

As can be seen by the chart the State of New York exceeds the F.M.V.S.S.-217 Section S5.2.3.1(a) by the addition of one or two extra doors.

Our request is that we be permitted to place a seat in the side door opening (Ref. 5.4.2.1(b). In other words, the last sentence of this section "A vertical Transverse, etc. . . . . . ." be declared null and void, yet the placement of the seat in relation to the door and for seat to the rear would not prevent the door to be used as an emergency exit.

To qualify as an emergency exit, seat placement and the door opening would permit the passage of the ellipsoid as specified in S5.2.2(b).

Should you desire additional information, kindly contact the writer.

James Tydings, Specifications Engineer