Interpretation ID: aiam3043
Director of Engineering
Wayne Corporation
Industries Road
Post Office Box 1447
Richmond
IN 47374;
Dear Mr. Kurre: This responds to your June 11, 1979, letter asking whether sid push-out window exits in school buses installed pursuant to State requirements must be marked in accordance with the emergency exit requirements of S5.5.3 of Standard No. 217, *Bus Window Retention and Release*. In particular, you want to know whether these additional exits must be labeled on the bus exterior.; Section S5.5.3 of the standard requires that '[e]ach school bu emergency exit provided in accordance with S5.2.3.1 shall have the designation....on both the inside and outside surfaces of the bus. Section S5.2.3.1, in turn, requires that school buses be equipped with a rear emergency door or a side emergency door and a rear push-out window. Taken together, these two sections require that the required rear or side emergency door or rear push-out window must be appropriately marked on the inside and outside of the bus.; As the agency has frequently stated, all exits installed in schoo buses beyond those required by S5.2.3.1 need not comply with the exit requirements applicable to school bus exits. All additional exits must comply, however, with the other sections of the standard applicable to non-school buses. In this case, the additional exits would be required to be labeled in accordance with Sections S5.5.1 and S5.5.2 of the standard. Neither of these paragraphs requires the exit to be marked on the bus exterior.; Sincerely, Frank Berndt, Chief Counsel