Interpretation ID: nht75-4.38

DATE: 03/31/75

FROM: AUTHOR UNAVAILABLE; R. B. Dyson; NHTSA

TO: Blue Bird Body Company

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of February 6, 1975, asking whether paragraph S5.5.1 of Motor Vehicle Safety Standard No. 217 (49 CFR 571.217) permits the words "Emergency Exit" to be placed above the emergency door in a school bus, or whether they must be within six inches of the emergency door release mechanism. You argue that placing the nomenclature above the door provides a more prominent identification of the exit than does placing it within 6 inches of the release mechanism.

We believe the interpretation of S5.5.1 which you suggest is appropriate when applied to rear door emergency exists in school buses. We have not previously considered school buses containing this type of emergency exit labeling to fail to conform to the standard. In addition, our recent proposal regarding school bus emergency exits (39 FR 8569, copy enclosed) would specifically require emergency exit labeling of this type.

YOURS TRULY,

February 6, 1975

Richard Dyson Assistant Chief Council U.S. Department of Transportation NHTSA

A question of interpretation has risen with regard to FMVSS 217. Paragraph S5.5.1 of that standard reads in pertinent part: "Each pushout window or other emergency exit shall have the designation "Emergency Exit", followed by concise operating instructions, located within six inches of the release mechanism. . .". The question is, must the words "Emergency Exit" be within six inches of the operating mechanism or is it sufficient to provide operating instructions within six inches of the release mechanism with the "Emergency Exit" marking shown in another and more prominent location?

We would point out that if the "Emergency Exit" designation must be within six inches of the operating mechanism, it is often not visible to occupants not in the immediate vacinity of the exit. This is because of the lettering size limit imposed by the spacial requirements of being within six inches of the operating mechanism.

Apparently there is some confusion regarding this matter since several states have asked our interpretation concerning it. Before FMVSS 217 became effective, most states required "Emergency Exit" or "Emergency Door" in letters at least two inches high immediately above each emergency exit. This system is well liked by those in the industry and, as shown in the attached photo, provides prominent identification of the exit for most occupants in the bus. We feel this method of providing emergency exit identification and operating instructions meets the requirements of S5.5.1 and would like to continue using this system.

Thank you for your consideration in this matter.

W. G. Milby

Staff Engineer