Interpretation ID: aiam1565
Project Engineer
The Adams & Westlake Company
1025 North Michigan Street
Elkhart
IN 46514;
Dear Mr. Hansing: This is in reply to your letter of July 3, 1974, regarding Moto Vehicle Safety Standard No. 217. You requested that we reconsider our opinion of June 11, 1974, that a bus emergency release mechanism which you describe must meet the requirements for emergency exit release in S5.3.2 of the standard after as well as before the retention test required by S5.1, when the glass breaks during the retention test.; Paragraph S5.3.2 requires that the release requirements be met bot before and after the retention test. We do not find sufficient justification to relax this requirement in the situation you described. First, it is not clear that it is as easy as you represent to eliminate by hand all of the glazing material left in the frame. More importantly, however, we still question whether most persons are sufficiently cognizant of the qualities of tempered glass to attempt to remove the remaining fragments in an emergency situation. Finally, glazing with completely different breakage characteristics may be used to replace the original tempered glass at some time during the life of the bus. For these reasons, our conclusion of June 11 remains the same.; Yours truly, Richard B. Dyson, Acting Chief Counsel