Interpretation ID: nht94-3.4

TYPE: INTERPRETATION-NHTSA

DATE: May 19, 1994

FROM: Paul L. Anderson -- President, Van-Con Inc.

TO: John Womack -- Acting Chief Council, NHTSA

TITLE: Re: Reflective Tape "Outlined Around Its Perimeter" For Emergency Rear Doors On Type A-1 Sixteen & Twenty Passenger School Buses Under 10,000 Lbs. Gross Vehicle Weight.

ATTACHMT: Attached To Letter Dated 6/8/94 From John Womack To Paul Anderson (A42; Std. 217)

TEXT: Dear Mr. Womack:

Thank you for your clairification of my questions May 2, 1994 letter. You stated that the Emergency Rear Doors of Type A-1 School Buses must be outlined around the perimeter with reflective tape. This brings up a question of tape installation due to th e existance of door hinges, O.E.M. tail light position, and the proximate position of Rear Door bottom edge to bumper.

There is no problem with installing reflective tape across the top and above both doors (see enclosed picture of rear doors on color brochure). There is also no problem running the tape down the left and right sides of the two doors, although the tape w ould not be continuous due to door hinges and the tail light lenses. Tape on the hinges would not last long because water, dirt, snow and ice would get behind it and lift it off also it would be a mess. The tail light lens comes within less that 1/2 in ch of door edge and I don't think it would be a good idea to run the tape over the tail light lens.

The bottom of the Emergency Rear Doors closes on a rubber gasket that touch the anti-hitch filler strip that closes the gap between the bumper and the bus body so there is no place to put reflective tape on the outside perimeter of the door bottom unless it is put on the bottom of the doors in which case it would not be on the "outside perimeter".

Question: Would we be in compliance with Reflective Tape requirements of FMVSS 217 if we put a continous strip of tape across the top of both Emergency Rear Doors on the roof cap above the doors and downthe left and right side of the double door opening with breaks in the tape for door hinges & tail light lenses. This would outline the Emergency Rear Doors on three sides. No tape would be put across the bottom?

As an alternative, if the above is not acceptable, could we put tape across the bottom on the doors?

Very truly yours,