Interpretation ID: aiam1427
Chief
Carrier Inspection Section
New York State Dept. of Transportation
1220 Washington Avenue
State Campus
Albany
NY 12226;
Dear Mr. Chauvin: This is in reply to your letter of January 7, 1974, inquiring whethe the words emergency door' may be used in lieu of emergency exit' under S5.5 of Motor Vehicle Safety Standard No. 217. You indicate that New York's regulations manual specifies the use of the words, emergency door,' and that a revised printing of the manual presently under way still contains this requirement.; While the NHTSA does not consider the phrase emergency door' to b synonymous with emergency exit (we do not believe push-out windows or other non-door emergency exits are appropriately marked emergency door'), we would not consider a bus to fail to conform to Standard No. 217 if its emergency doors were marked emergency door.' Emergency exits other than doors, however, must be marked emergency exit.; NHTSA standards apply only to vehicles manufactured after a standard' effective date. Standard No. 217 does not apply to buses in use that were manufactured before its effective date of September 1, 1973.; I point out that the provisions of the National Traffic and Moto Vehicle Safety Act dealing with preemption of State requirements (15 U.S.C. 1392(d)) prohibit New York from enforcing its requirement that emergency exits be marked emergency door.'; Sincerely, Lawrence R. Schneider, Chief Counsel