Interpretation ID: aiam2899
Wayne Corporation
P. O. Box 1447
Industries Road
Richmond
IN 47374;
Dear Mr. Kurre: This responds to your September 6, 1978, letter asking for clarification of the requirements of Standard No. 217, *Bus Window Retention and Release*. In particular you ask whether paragraph S5.3.3 which requires that, 'a continuous warning sound shall be audible at the driver's seating position and in the vicinity of the emergency exit door having the unclosed mechanism' means that there must be a separate warning alarm at each emergency door and a warning alarm in the driver's seating area.; In your letter you recite the early history of this standard whic addresses the alarm system requirement. At the time of the final rule's adoption, commenters questioned the requirement in the same manner that you have questioned it in your letter. The agency stated in the preamble to the final rule (41 FR 3871) that the requirement mandated the use of audible alarms at each door and in the driver's seating location. The rationale for that requirement was outlined in the preamble and referenced in your letter. Since this interpretation of paragraph S5.3.3 was part of the initial rulemaking with respect to this standard, it is not necessary for the agency to undertake further rulemaking at this time to make this requirement binding upon manufacturers. The multiple alarm system requirement has been the agency's interpretation of paragraph S5.3.3 since its issuance, and manufacturers are required to comply with the safety standards as they are interpreted by the agency.; Sincerely, Joseph J. Levin, Jr., Chief Counsel