Interpretation ID: aiam3631
Director of Engineering
Thomas Built Buses Inc.
1408 Courtesy Road
P.O. Box 2450
High Point
NC 27261;
Dear Mr. Mathieson: This responds to your September 13, 1982, letter concerning you 'vandalock' system and Standard No. 217, *Bus Window Retention and Release*.; Section S5.2.3.2 states that 'the engine starting system of a schoo bus shall not operate if any emergency exit is locked from either inside or outside the bus. For purpose of this requirement, 'locked' means that the release mechanism cannot be activated by a person at the door without a special device such as a key or special information such as a combination.' You state that your locking mechanism, which is a bolt device, doesn't meet the definition of 'locked' since it requires neither a key nor special instructions. You further indicate that the engine will not start until the bolt is withdrawn.; We disagree that your bolt when in the closed position would not mee the definition of locked. The door would not be capable of opening from the outside without the use of special devices when the bolt was closed. Accordingly, the door would be considered locked.; However, nothing in Standard No. 217 prohibits the installation o locking doors as long as the vehicle cannot be started with the door in the locked position. As you noted, your vandalock system is designed to prevent the starting of a vehicle in such circumstances.; Sincerely, Frank Berndt, Chief Counsel