Interpretation ID: 9549
Manager, Engineering Services
Blue Bird Body Company
P.O. Box 937
Fort Valley, GA 31030
Dear Mr. Turner:
This responds to your letter of January 6, 1994, asking several questions concerning a recent amendment to Standard No. 217, Bus Emergency Exits and Window Retention and Release (57 FR 49413; November 2, 1992). Our response to each of your questions follows.
1.Your first question requested confirmation that a left side emergency exit door required by S5.2.3.1(a)(2)(i) would meet the location requirements of S5.2.3.1(a)(2)(i) if it is located in the center one- half of the passenger compartment.
Your question concerns the first required additional emergency exit installed on a bus with a rear emergency exit door. Section S5.2.3.2(a)(2) requires this exit to be a side emergency exit door "located on the left side of the bus and as near as practicable to the midpoint of the passenger compartment." Locating the door or the 12-inch required aisle opening for the door in the center one-half of the passenger compartment would not ensure compliance with this requirement. This is because it may be possible to locate a door in the center one-half without locating the exit "as near as practicable to the midpoint of the passenger compartment." In determining the permissible location for this exit, you should determine where the exit would be located if it was located at the midpoint of the passenger compartment. If it is not practicable to locate the exit there, you should move the door only as far as necessary for a practicable location.
2.Your second question requested confirmation that there are no fore and aft location requirements for side emergency exit doors other than the requirements for a left side emergency exit door required by S5.2.3.1(a)(2)(i).
You are correct. Except for a left side emergency exit door installed as the first additional emergency exit on a bus with a rear emergency door, the only location requirements for side emergency exit doors concern the side of the bus on which the exit must be located. I have attached for your information an appendix which lists all the location requirements for additional emergency exits.
3.Your third question requested confirmation that all side emergency exit doors, including any voluntarily installed, are required to comply with the requirements of the new final rule, including the seat placement requirements in S5.4.2.1(b).
You are correct. Your letter referred to a March 9, 1977 interpretation that voluntarily installed side emergency exit doors were not required to meet the school bus requirements, but were required to meet the non-school bus requirements. Previously, the school bus emergency exit door requirements in Standard No. 217 referred to "the emergency door." At that time school buses were required to have either one rear emergency exit door or one side emergency exit door and one rear push-out window. Thus, any school bus was required to have only one emergency exit door. The reference to "the emergency door" was to the required door.
In the recent amendments to Standard No. 217, some of the performance requirements for emergency exits apply to "each" emergency exit. See, for example, S5.4.2.1(b). This change in the language extends these requirements to any emergency exit door in a school bus. Other requirements apply to "required" emergency exits. See, for example, S5.5.3(c). These requirements do not apply to voluntarily installed emergency exits.
I hope you find this information helpful. If you have any other questions, please contact Walter Myers of my staff at this address or by phone at (202) 366-2992.
Sincerely,
John Womack Acting Chief Counsel
Enclosures
ref:217 d:4/14/94