Interpretation ID: nht93-9.11

DATE: December 13, 1993

FROM: Lawrence P. White -- Acting Director, Bureau of Motor Vehicles, Commonwealth of Pennsylvania, Dept. of Transportation

TO: Mary Versie -- NHTSA, School Bus Regulations

TITLE: None

ATTACHMT: Attached to letter dated 3/21/94 from John Womack to Lawrence P. White (A42; Redbook; Std. 217)

TEXT:

I am writing concerning the new school bus emergency exit requirements in the FMVSS 217.

My office has received numerous inquiries from Pennsylvania's law enforcement agencies, school bus sales representatives and school bus contractors, concerning the new school bus exit requirements. These questions are:

1. The effective date - is it the chassis manufacturer's date of completion, the final stage manufacturer's date of completion, or somewhere in between?

2. Based on the formula for emergency exit space, is the area of the front entrance door to be included? Does this mean on a vehicle of 60 to 77 passengers, the only additional requirements beyond the front and rear doors is a left side exit door?

3. The "clear aisle space" required for exit to the proposed side emergency door, according to federal specifications, can be met with a flip- up type seat or a clear opening of 12", as measured from the back of the door forward. Are there any specifications, definitions, or descriptions provided as to what would be considered a "flip seat"?

4. Also, there is concern regarding school buses that are equipped with the "flip seat" by the emergency door opening and the possibility of school children, either intentionally or accidentally, unlatching the door latch mechanism. Are the door latch mechanisms to be equipped to help prevent this from occurring?

In the interest of maintaining the integrity of school buses, I am inquiring as to the correct responses to these questions and concerns.

Thank you for your assistance on this matter.