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Interpretation ID: aiam2425

Mr. Richard B. Ansell, Anschelewitz, Barr, Ansell & Bonello, 513 Bangs Avenue, Asbury Park, NJ 07712; Mr. Richard B. Ansell
Anschelewitz
Barr
Ansell & Bonello
513 Bangs Avenue
Asbury Park
NJ 07712;

Dear Mr. Ansell: This responds to your September 8, 1976, question whether the window of recreational vehicles' qualify as secondary means of egress' and what Federal requirements would apply to them if they do so qualify.; The only Federal requirement for the provision of emergency exits appl to buses (Standard No. 217, *Bus Window Retention and Release*, 49 CFR 571.217 (copy enclosed)). Bus' is defined by our regulations to mean a motor vehicle with motive power, except a trailer, designed for carrying more than 10 persons (49 CFR 571.3). Thus, Standard No. 217 would apply to the vehicle you describe if it is designed to carry more than 10 persons (including the driver) while the vehicle is in motion.; The standard does not use the term secondary means of egress' bu specifies a minimum area of unobstructed opening that may be provided by several means (*e.g.*, emergency door, push-out window').; Sincerely, Frank A. Berndt, Acting Chief Counsel