Interpretation ID: 9792
Mid Bus
3555 St. Johns Road
P.O. Box 1985
Lima, OH 45802-1985
Dear Mr. Stewart:
This responds to your letter of March 17, 1994, regarding a final rule published November 2, 1992 (57 FR 49413) amending Standard No. 217, Bus Emergency Exits and Window Retention and Release. You requested clarification of the width requirement in S5.5.3(c) for retroreflective tape.
You are correct that there was a discrepancy concerning the size of the tape caused by the metric conversion in the final rule. Enclosed is a copy of a July 7, 1993 letter to Mr. Thomas D. Turner of the Blue Bird Body Company which discusses this issue. As explained in that letter, we plan to issue a correction notice of the November 2, 1992 rule that would specify a minimum size of 2.5 cm for the tape. Until the correction is issued, we will not take enforcement measures regarding tape size against a manufacturer who uses 1 inch wide retroreflective tape.
I hope you find this information helpful. If you have any other questions, please contact us at this address or by phone at (202) 366-2992.
Sincerely,
John Womack Acting Chief Counsel
Enclosure
ref:217 d:4/l/94