Interpretation ID: nht74-3.15

DATE: 02/27/74

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Excel Industries

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of January 14, 1974, inquiring whether Motor Vehicle Safety Standard No. 217, "Bus Window Retention and Release" (49 CFR 571.217), prohibits the use of sliding windows as emergency exits in buses. You refer to language in S5.3.1 and S5.4 of the standard which refers specifically to the use of push-out windows as emergency exits.

Standard No. 217 is not intended to prohibit the use of sliding windows as bus emergency exits, but such windows must comply with all of the standard's requirements for emergency exits.

Yours truly,

January 14, 1974

Lawrence Schneider

NHTSA

Excel Industries has, in the past few years, been in the production of a sliding window that is used in multi-purpose vehicles, motor homes, trailers, and other related recreational vehicles. With the energy crisis, some of our customers are attempting to convert these motor homes into people carriers, limousines, airport buses, ski lodge transportation, etc.

Under amendments to paragraphs (a), (b) and (c) of 393.61 and amendments to 393.63 of the Motor Carrier Safety Regulations as published in the Federal Register on June 10, 1972, "On a bus manufactured on and after September 1, 1973, having a seating capacity of more than 10 persons, each push-out window shall conform to Motor Vehicle Safety Standard No. 217, Part 571 of this title."

Furthermore, under Motor Vehicle Safety Standard No. 217, paragraph S5.2.1, it states that unobstructed opening requirements are to be provided which conform to S5.3 through S5.5 for vehicles with a GVWR of greater than 10,000 lb. Paragraph S5.2.2 states the unobstructed openings for buses with a GVWR of less than 10,000 lb. Under subparagraph (b) of this paragraph, it merely states, "Windows that can be opened manually to a position that provides an opening large enough to admit. . . ." etc. In reviewing these standards, we feel that our windows would definitely conform to the buses defined in S5.2.2 and, by meeting the window retention requirements in S5.1 and the emergency release requirements in S5.3, our window would conform to the definition of an emergency exit for buses defined in S5.2 except for the wording on push-out windows or other emergency exits, Paragraph S5.3.1 and S5.3.2, "The release mechanism or mechanisms shall require for release. . . . . of the initial push-out motion of the emergency exit (outward and perpendicular to the exit surface.)" In re-reading these specs, many references are made to windows as being push-out windows. However, in discussing this with Mr. Frank Bergsman of your Standards Office (ph. 202-426-2807), he feels that, if our sliding window can be opened to permit the 20x13 ellipsoid to pass through it, our window could conform as an emergency exit in both paragraphs; i.e., S5.2 for over 10,000 lb. buses and S5.2.2 for buses of 10,000 lb. or less.

Mr. Bergeman has said he has discussed this spec with you, and we would like a written reply on this interpretation as soon as possible.

S. A. Spretnjak

Chief Design Engineer

(Graphics omitted)

EXCEL INDUSTRIES

PARADE OF NEW PRODUCTS

FOR THE MOBILE HOME AND R.V. INDUSTRY

ROUND CORNERED BAGGAGE DOOR

SQUARE CORNERED BAGGAGE DOOR

MOTOR HOME SEAT PEDESTAL

ROUND CORNERED SLIDING WINDOW

VAN SCREENS

MOBILE & MODULAR SINGLE HUNG WINDOW

CAMPER TAILGATE SPRING LIFT ASSIST