Interpretation ID: aiam3680
P. Eng.
Flyer Industries Limited
64 Hoka Street
Box 245 Transcona P.O.
Winnipeg
Manitoba
Canada R2C 3T4;
Dear Mr. Moss: This responds to your January 27, 1983, letter asking about th application of Standard No. 217, *Bus Window Retention and Release*, to the front entrance doors of buses. You ask that the window retention test not be applied to your bus, because application of the required amount of force will cause the door to open. You state further that if the door had no glazing, it would not be tested for retention and, therefore, would be acceptable under the standard.; Standard No. 217 states that all glazing that exceeds 8 inches i diameter shall be tested for retention. During that test, neither the glazing nor the surrounding frame shall open in a manner that would allow a 4-inch sphere to pass through the opening. The intent of this requirements is of course to prevent the ejection of occupants in accidents.; The agency does test the front door of buses for compliance with thi section if they contain glazing that meets the size requirement. In tests that have been conducted, most front doors have complied. Accordingly, the proper construction of front doors in compliance with the requirement would not appear to be a problem. The agency does not believe that it would be in the interest of safety to exempt front door glazing from the test requirements. Although passengers are required to stand behind the standee line as you note in your letter, they may easily be thrown forward of that line in an accident. The agency considers it important to reduce the possibility of their being thrown from the vehicle if such a situation were to arise.; You are technically correct that an all metal door would not be teste for compliance with this retention provision since it would not contain glazing. However, the agency would not view favorably the installation of doors in buses that open so easily in an accident. Use of such doors might be considered to be a safety-related defect subject to the agency's recall and remedy authority.; Sincerely, Frank Berndt, Chief Counsel