ID: nht78-3.15

DATE: 07/17/78

FROM: AUTHOR UNAVAILABLE; J. J. Levin, Jr.; NHTSA

TO: Automobile Importers of America

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your recent letter asking whether passive safety belts are exempt from the requirements of Safety Standard No. 209, Seat Belt Assemblies.

The answer to your question is yes, with one exception. Paragraph S4.5.3.4 of Safety Standard No. 208, Occupant Crash Protection, specifies that passive safety belts that are not required for the vehicle to meet the perpendicular frontal crash protection requirements of the standard must meet the requirements of Standard No. 209. Therefore, only passive belts that are installed to meet the frontal crash protection requirements of Standard No. 208 are exempted from the requirements of Standard No. 209.

Sincerely,

June 8, 1978

Joseph Levin Chief Counsel National Highway Traffic Safety Administration

Dear Mr. Levin: Subject: Request for an Interpretation FMVSS 208/209

In reviewing the requirements presented in FMVSS 209, Seat Belt Assemblies in connection with the design of passive belt systems, there appears to be no distinction between the applicability of the standard as to active and passive belt systems. In reviewing FMVSS 208, Occupant Crash Protection however, paragraph 4.5.3.4 appears to exempt passive belt systems from compliance in any manner with the requirements of FMVSS 208. Since such an exemption would provide the design latitude necessary in the development of an optimum passive belt system, I would appreciate your confirmation that this exemption is intended.

In view of the extensive development efforts now underway in the engineering departments of many manufacturers, an expeditious response to this request would be appreciated.

George C. Nield President

ID: nht78-3.16

DATE: 11/09/78

FROM: AUTHOR UNAVAILABLE; Joan Claybrook; NHTSA

TO: Hon. Bob Wilson - H.O.R.

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of October 17, 1978, concerning a telephone call from your constituent, Mr. Stefan Dagrowski, urging standardization of the type of release on seat belts.

Federal Motor Vehicle Safety Standard No. 208, Occupant Crash Protection, issued March 10, 1971 (36FR4600), required that effective January 1, 1972, passenger car seat belt assemblies would be released at a single point by push button action. To that extent, the type of release on seat belts is standardized since our standards are primarily performance oriented, and the manufacturers are free to design however they wish to meet those performance requirements.

I hope this information is sufficient to satisfy Mr. Dagrowski's interest in standardized seat belt releases.

SINCERELY,

Congress of the United States House of Representatives

October 17, 1978

Dear Ms. Claybrook:

I recently received a telephone call from a constituent, Mr. Stefan Dagrowski, urging standardization of the type of release on seat belts.

Your advice and counsel as to anything currently underway in this regard, which I can pass along to Mr. Dagrowski, will be greatly appreciated.

Thank you for your attention to this matter and kind regards.

Bob Wilson Member of Congress

Honorable Joan Claybrook National Highway Traffic Safety Administration

ID: nht78-3.17

DATE: 09/27/78

FROM: AUTHOR UNAVAILABLE; J. J. Levin, Jr.; NHTSA

TO: Wayne Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your recent letter asking whether Safety Standard No. 208 applies to side-facing seats in multipurpose passenger vehicle vans. You also ask to be advised of the criteria to be used for the installation of seat belts in these vehicles.

Safety Standard No. 208, Occupant Crash Protection, does require side-facing seats in multipurpose passenger vehicles to comply with one of the options under paragraph S4.2.2, since the side-facing seats in question would be considered designated seating positions. If a manufacturer chooses to install seat belts under one of the options of that paragraph, the seat belt assemblies must comply with Safety Standard No. 209, Seat Belt Assemblies, and Safety Standard No. 210, Seat Belt Anchorages.

Safety Standard No. 210 does exempt side-facing seats from its strength requirements, but all other requirements of the standard would be applicable. However, we strongly recommend that belt anchorages for side-facing seats be of at least equivalent strength to anchorages for forward and rearward facing seats, since the strength specifications are only minimum performance requirements. Side-facing seats were excepted from the strength requirements specified in the standard because the forces acting on side-facing seats are different from those acting on forward or rearward facing seats and the requirements and procedures were specifically developed for these latter seats.

Please contact this office if you have any further questions.

SINCERELY,

Wayne Corporation

August 24, 1978

Office of Chief Counsel National Highway Traffic Safety Adm.

Gentlemen:

The Wayne Corporation manufacturers small buses (GVWR 10,000 lbs. and under), Busette and Transette, which have a normal passenger capacity of 16 to 20 passengers.

Some of these buses are equipped to accommodate transporting the handicapped. In some of these cases, the operators' requirements for lifts, wheelchair anchorage devices, side facing seats, etc., reduced the passenger capacity to less than 10 persons, in which case the vehicle becomes, for purpose of Federal Certification, a multipurpose passenger vehicle rather than a bus.

Which, if any, of the requirements of FMVSS 208, Passenger Crash Protection, apply to side facing seats installed in the MPV discussed above?

If you should find that S4.1.2.3 of FMVSS 208 applies at the option of the manufacturer, please advise the criteria to be used for the installation of the seat belts, taking into consideration that all current seat belt requirements relate only to forward and rearward facing seats.

Robert B. Kurre Director of Engineering

ID: nht78-3.18

DATE: 02/16/78

FROM: AUTHOR UNAVAILABLE; J. J. Levin, Jr.; NHTSA

TO: Volvo of America

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your letter of December 20, 1977, enclosing a previous letter requesting an interpretation of paragraph S4.3(j) of Safety Standard No. 209, Seat Belt Assemblies. I am sorry that your earlier letter was misplaced.

Volvo is correct in its interpretation that the requirements for emergency locking retractors in S4.3(j)(2) and (3) were promulgated for reasons of comfort and convenience, although this in turn is directed toward a safety objective. As you know, the more comfortable and convenient belts are, the more likely they will be worn by motorists. Further, the requirements in these paragraphs assure that the driver can make necessary movements in the occupant compartment safely.

Paragraph S4.3(j)(2) specifies that an emergency locking retractor

"shall not lock, if the retractor is sensitive to webbing withdrawal, before the webbing extends 2 inches when the retractor is subjected to an acceleration of 0.3g or less."

Volvo interprets this to require that the retractor not lock before the webbing extends 2 inches when the webbing is subjected to an acceleration of 0.3g. This is incorrect. The requirement specifically states that the retractor is to be accelerated. The agency does not agree that keeping the belt stationary and accelerating the retractor is equivalent to keeping the retractor stationary and accelerating the belt. This is due to the fact that inertial forces react upon the retractor during its acceleration that are not present when the webbing alone is accelerated. Therefore, results from the two methods of testing could differ significantly.

I hope this has been responsive to your inquiry, and if we can be of any further assistance please let us know.

Sincerely,

ATTACH.

December 20, 1977

Hugh Oates -- Office of Chief Council, National Highway Traffic Safety Administration

Dear Mr. Oates:

As per our telephone conversation, enclosed is one copy of Volvo's Request for Interpretation FMVSS #209 dated April 4, 1977.

We are looking forward to your response to this request for interpretation.

If additional information is required on this subject, don't hesitate to contact the undersigned.

Sincerely yours, William Shapiro PE -- Regulatory Analysis Engineer

ENC.

April 4, 1977

Frank Berndt -- National Highway Traffic Safety Administration

Re: Request for Interpretation FMVSS #209

Dear Mr. Berndt,

Volvo requests interpretation of certain provisions in Section 4.3(j) of FMVSS #209.

S4.3 (j) Emergency-locking retractor

An emergency-locking retractor of a Type 1 or Type 2 seatbelt assembly, when tested in accordance with the procedures specified in paragraph S5.2(j) -

(1) Shall lock before the webbing extends 1 inch when the retractor is subjected to an acceleration of 0.7g;

(2) Shall not lock, if the retractor is sensitive to webbing withdrawal, before the webbing extends 2 inches when the retractor is subjected to an acceleration of 0.3g or less;

(3) Shall not lock, if the retractor is sensitive to vehicle acceleration, when the retractor is rotated in any direction to any angle of 15 degrees or less from its orientation in the vehicle.

It is our interpretation that the requirements in Section 4.3(j)(1) were promulgated for safety reasons, while the requirements in Section 4.3(j)(2) & (3) were promulgated for comfort requirements for webbing acceleration sensitive retractors and vehicle acceleration sensitive retractors respectively.

Because we believe that the requirements in Section 4.3 (j)(2) were promulgated to prevent premature locking of the retractor when the webbing is being withdrawn, we interpret this to require that the retractor shall not lock before the webbing extends 2 inches when the webbing is subjected to an acceleration of 0.3 g or less. Is this interpretation correct? Also, we would like to point out that in our opinion testing the emergency-locking retractor system in the following two manners gives the same results.

1) Keeping the belt stationary and accelerating the retractor and

2) Keeping the retractor stationary and accelerating the belt.

If there are any questions pertaining to this issue, please feel free to contact me at your convenience.

In advance, thank you for your attention to this matter.

Sincerely, William Shapiro, P.E. -- Regulatory Analysis Engineer

ID: nht78-3.19

DATE: 04/05/78

FROM: AUTHOR UNAVAILABLE; F. Berndt for J. J. Levin, Jr.; NHTSA

TO: Grumman Flxible Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your recent letter asking whether Safety Standard No. 209, Seat Belt Assemblies, and Safety Standard No. 210, Seat Belt Anchorages, would be applicable to a Type I seat belt assembly used as a securement device for wheelchairs in an urban transit bus.

Safety Standard No. 209 is an equipment standard that is applicable to any seat belt manufactured for use on passenger cars, multipurpose passenger vehicles, trucks or buses. Therefore, the seat belt in question would have to comply with the performance requirements of that standard.

Safety Standard No. 210, however, only specifies requirements for seat belt anchorages at the driver's position on buses. Since the assembly you are concerned with would be at a passenger seating position in the bus, it would not have to comply with the anchorage requirements of Standard No. 210.

SINCERELY,

GRUMMAN FLXIBLE CORPORATION

February 10, 1978

Office of the Chief Counsel National Highway Traffic Safety Administration

Attention: Hugh Oats

Dear Mr. Oats:

The Grumman Flxible Corporation is using an extra-long, Type 1 seat belt as a wheelchair securement device in association with the wheelchair accessibility option required by 49 CFR 609.15(c) for installation in urban transit buses. This seat belt is used in conjunction with an adjustable, padded arm extending from the vehicle wall area which can be positioned in front of the forward facing wheelchair passenger.

Is this seat belt subject to the requirements of FMVSS No. 209, Seat Belt Assemblies?

Is the anchorage for this seat belt assembly, installed in a transit bus at a location other than at the driver's position, subject to the requirements of FMVSS No. 210, Seat Belt Assembly Anchorages?

We appreciate very much your assistance with the above.

R. L. Ratz, P.E. Product Safety Engineering

ID: nht78-3.2

DATE: 01/25/78

FROM: AUTHOR UNAVAILABLE; J. J. Levin, Jr.; NHTSA

TO: Toyo Kogyo Co., Ltd.

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of December 14, 1977, inquiring whether attaching mirrors onto the backs of sun visors on the passenger's side would violate S3.4.1 of Motor Vehicle Safety Standard No. 201, Occupant Protection in Interior Impact -- Passenger Cars.

The National Highway Traffic Safety Administration has determined that paragraph S3.4.1 of Standard No. 201 does not prohibit the installation by manufacturers of vanity mirrors on sun visors. Consequently, so long as the mirror does not cause the visor to be hazardous or to interfere with the energy-absorbing requirement of S3.4.1, manufacturers are free to incorporate such mirrors into or onto sun visors, including fitting mirrors onto the backs of the sun visors on the passenger's side as in the diagram you enclosed.

SINCERELY,

Toyo Kogyo Co., Ltd.

December 14, 1977

Joseph J. Levin, Jr. Chief Counsel National Highway Traffic Safety Administration U.S. Department of Transportation

Dear Mr. Levin:

We are considering to attach a mirror to the sun visor for customers' convenience. However, since MVSS 201 provides for the following requirement, we would like to have your comment as to whether we can meet it by doing so.

MVSS 201 "Occupant Protection in Interior Impact"

S3.4 Sun visor

S3.4.1 Two sun visor shall be provided that are constructed of or covered with energy-absorbing material.

The mirror will be fitted into the back of the sun visor on passenger's side as shown in the attached sheet. We consider that this would be in compliance with the above requirement on the grounds that the sun visor made of energy-absorbing material would not contact the occupant under normal condition, thus would not produce an adverse effect on the safety of the occupant.

We would appreciate hearing from you on this matter as soon as possible.

Moriyuki Watanabe Director and Assistant General Manager Research and Development

CC: TOYO KOGYO USA REP. OFC., DETROIT BRANCH

(Graphics omitted)

ID: nht78-3.20

DATE: 08/18/78

FROM: AUTHOR UNAVAILABLE; J. J. Levin, Jr.; NHTSA

TO: Alfa Romeo, Inc.

TITLE: FMVSS INTERPRETATION

ATTACHMT: ATTACHED TO LETTER DATED 10/13/88 TO PAUL UTANS FROM ERIKA Z JONES, REDBOOK A32 STANDARD 208, STANDARD 210; LETTER DATED 08/11/88 TO ERIKA Z JONES FROM PAUL UTANS, OCC - 2405; LETTER DATED 12/01/86 TO FRANCOIS LOUIS FROM ERIKA Z JONES, STANDARD 208

TEXT: This responds to your recent letter concerning Alfa Romeo's proposed designs for Type 2 seat belt assemblies to be used on convertibles. You ask for clarification of the anchorage location requirements specified in Safety Standard No. 210, as they would apply to your proposed designs.

Paragraph S4.1.1 of Safety Standard No. 210, Seat Belt Assembly Anchorages, specifies that anchorages for a Type 2 belt shall be installed for each forward-facing outboard designated seating position in passenger cars other than convertibles. Manufacturers are permitted to install Type 2 belts in convertibles, however, under paragraph S4.1.2 of the standard which specifies that either a Type 1 or Type 2 belt may be installed for designated seating positions not required to have Type 2 belts under the previous section.

Since convertibles are only required to have Type 1 belts, only the pelvic portion of your proposed Type 2 designs must meet the anchorage location requirements of the standard. These location requirements are specified in S4.3.1, and the pelvic portion of your two proposed designs (Figures 2 and 3 in your letter) appear to fall within the 20 degrees - 75 degrees acceptable range. The upper torso portions of the belt designs do not have to comply with the 40 degrees acceptable range specified in S4.3.2, since those portions are in addition to what is required by the standard.

In response to your general question, "seat belt anchorage" is defined in Standard No. 210 as the "provision for transferring seat belt assembly loads to the vehicle structure." For purposes of determining compliance with the anchorage location requirements of the standard, the agency interprets anchorage to include any load-bearing element of the seat belt assembly that is capable of meeting the force requirements of Standard No. 210. For example, in your Figure 1 you state that the lap belt is anchored "at point 'C' within the 40 degrees zone and then passes through a webbing guide anchorage." The 40 degrees zone is not the applicable location requirement for lap belts and if this were the only anchorage, the belt would not comply with the standard. However, since the "webbing guide anchorage" appears to be within the applicable 20 degrees-75 degrees zone, the belt would be in compliance if that anchorage is capable of meeting the force requirements of the standard. The agency considers an assembly to be in compliance if there is one force-complying anchorage within the acceptable ranges specified in the standard, and that anchorage is determinative of the angle the belt crosses the vehicle occupant.

To summarize, both of your proposed Type 2 seat belt assemblies would comply with the location requirements of Standard No. 210 if used in convertibles, since only the pelvic portions of the assemblies would have to meet the requirements of the standard and the anchorages for those portions appear to be within the acceptable ranges. Further, either assembly design can be used in hard-top automobiles if it has one anchorage capable of meeting the force requirements of the standard that is located in the 40 degrees acceptable range for upper torso portions of Type 2 belts.

Please contact Hugh Oates of this office if you have any further questions concerning this subject (202-426-2992).

Sincerely,

Alfa Romeo, Inc.

May 12, 1978

Joseph J. Levin, Jr. Office of Chief Council U.S. Department of Transportation National Highway Traffic Safety Administration

RE: LOCATION OF ANCHORAGE FOR UPPER TORSO RESTRAINT REQUEST FOR CLARIFICATION

Dear Mr. Levin:

Due to recent changes in European law, the upper torso restraint anchor on the Alfa Romeo Spider (roadster) will have to be redesigned. Ideally, an upper torso restraint anchor that complies with both U.S.D.O.T. F.M.V.S.S. and European law in one common design is preferred.

To keep this request brief, we prefer to use graphic references:

DRAWING 1: (Figure 1)

This depicts presently produced U.S. model (115.41) Spider having a "type 1" belt assembly. This lap belt is anchored at point "C" within the 40 degrees zone and then passes through a webbing guide anchorage at outboard points and "B".

Unfortunately this system will not comply with the new European law. Therefore, we consider two alternate substitute designs described below.

DRAWING 2: (Figure 2)

This shows a proposed installation of a "type 2" (3 point) torso/lap harness. Here we see the retractor mounted on the floor (outside the 40 degrees zone) at point 4. The webbing is then fed through a guide anchorage at point 3 (within the 40 degrees zone) up to another webbing guide on the seatback at point 1.

In this proposal, while the retractor is outside the 40 degrees zone, the "anchorage guides" 3 and 1 are well within the acceptable zone. This poses the question as to what is the "anchorage" (i.e., the retractor or the "anchor"?). In mechanical theory the retractor could be outside the 40 degrees zone while the "anchorage" remained within the 40 degrees zone. Our view is that the intent of N.H.T.S.A.'s design limitation is to prevent the torso webbing from attaining a loadline of more than 40 degrees (for well known reasons). This proposal achieves the "intent" of the author of F.M.V.S.S. 210, even though in a "roundabout" manner.

We would like N.H.T.S.A.'s opinion as to whether or not this proposal demonstrates compliance with 210's "40 degrees Fig. 1 zone" by design.

DRAWING 3: (Figure 3)

This proposed design eliminates the point 3 roller of the previous design, for simplicity. Instead, the retractor is mounted "direct" but slightly outside the 40 degrees zone.

Now, at point 1 on the seatback, this guide is well within the acceptable zone. It is in reality the point that determines the position of the webbing in relation to the occupant's torso. (This point is referred to as the "effective point" in the European law. It is the last point at where the webbing changes direction).

Needless to say, the point 1 guide does have sufficient load bearing capability to consider it as an anchorage. It is not merely a "convenience loop" as used on some U.S. vehicles, but an integrally designed part of the seat back.

F.M.V.S.S. 210 S4.1.1

This requirement specifically states that anchorages for Type 2 belt assemblies "shall be installed . . . . . in passenger cars other than convertibles." Does this by exclusion ("shall - other than convertibles") prohibit the installation of Type 2 belt assemblies in convertibles - or does it infer Type 2 as an option?

If the Type 2 is prohibited in convertibles, then we must try and define the word "convertible." What determines "convertibility" and what are we "converting" (the top?). If we are "converting" from a closed to an open vehicle, when and what degree of "open-ness" determines that the vehicle is in fact "open" or a convertible. We feel this is academic and use it only as a means to demonstrate the vagaries of F.M.V.S.S. 210 requirements. We realize that we also are among the minority by virtue of our almost exclusive production of "convertibles".

Our design management would appreciate N.H.T.S.A.'s legal opinion as to the compliance capabilities of our proposals 2 and 3 as soon as is possible as we are delaying tooling pending your decision.

Should the enclosed drawings require clarification or further discussion, please let us know.

D. Black Manager U.S. Engineering Office

cc: ING. FOGLIATA -- DIPRE/LEGO ING. DIMORA -- DIPRE/CARR DIPRE/ESPE ESCA

(Graphics omitted)

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(Illegible Word) Present location SEAT BELT ANCHORAGES A-B-C SEAT BELT TYPE "1" PRESENT No DISEGNO Legn 115L1 ed 79 fg1

(Graphics omitted)

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ID: nht78-3.21

DATE: 07/26/78

FROM: AUTHOR UNAVAILABLE; J. J. Levin, Jr.; NHTSA

TO: T. Iinuma - Nissan Motor Co., Ltd.

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your May 25, 1978, question concerning the strength requirements of Safety Standard No. 210, Seat Belt Assembly Anchorages, as they would be applicable to the anchorage on a single diagonal passive belt system. You ask how many pounds of force should be applied to such a belt system for the anchorage strength test.

The anchorage for a single diagonal passive seat belt should be tested with a 3,000 pound force for purposes of the Standard 210 requirements, the same force required for the upper torso portion of a Type 2 seat belt. Most vehicles with single diagonal passive belt will have knee bolters or some other method to restrain the legs in a crash, so the anchorage will not experience as much stress as would be placed on a lap belt without knee bolsters. Therefore, 3,000 pound test should ensure that the anchorage for a diagonal passive belt can withstand typical crash forces.

SINCERELY,

NISSAN MOTOR CO., LTD.

May 25, 1978

Joseph J. Levin Chief Counsel NHTSA Department of Transportation

Dear Mr. Levin:

This letter is to request your interpretation regarding the test method of FMVSS 210 "Seat belt assembly anchorages". The force applied to the anchorage of Type 1 or Type 2 seat belt assembly is expressed clearly in that standard. (Type 1:5000 lbs., Type 2:lap portion 3000 lbs. and shoulder portion 3000 lbs. simultaneously).

It seems, however, there is no specific description of the force for the anchorage of the single diagonal passive seat belt (so called VW Rabbit type passive seat belt).

I would like to know how many pounds we should apply to the above mentioned passive seat belt for the anchorage strength test.

I look forward to hearing from you as soon as possible

Tokio Iinuma Staff, Safety

cc: WILLIAM E. SMITH -- CRASHWORTHINESS DIV., NHTSA

ID: nht78-3.22

DATE: 10/02/78

FROM: AUTHOR UNAVAILABLE; J. J. Levin, Jr.; NHTSA

TO: Ward Industries, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your August 22, 1978, letter asking whether your proposed emergency door label complies with the requirements of Standard No. 217, Bus Window Retention and Release.

Paragraph S5.5.3 requires that each school bus emergency exit shall have the designation "Emergency Exit" or "Emergency Door" as appropriate, in letters at least 2 inches high, of a color that contrasts with its background, located at the top of or directly above the emergency exit on both the inside and outside surfaces of the bus. The label that you propose would be located on the inside of the glass but would be visible from the outside of the vehicle.

The National Highway Traffic Safety Administration (NHTSA) has indicated in the past that the location of the emergency exit label can be directly above or on the top half of the emergency exit. Your location near the top of the glass on the rear emergency door appears to fall within this acceptable area. The standard further requires that the label be located on both the inside and outside surfaces of the bus. The intent of this requirement is to provide a visible emergency exit designation on both the inside and outside of a bus. Since your label would be visible outside the school bus even though its location would be on the inside of the glass, the NHTSA concludes that it complies with this requirement. In reaching this conclusion, the agency assumes that you will have a similar label that will be visible inside the bus.

In summary, since your described label is the required size, consists of contrasting colors, and is placed in the appropriate location, it appears to comply with the requirements of Standard No. 217.

SINCERELY,

WARD Industries Inc.

August 22, 1978

Joseph J. Levin, Jr. Chief Counsel National Highway Traffic Safety Admn.

Ref: FMVSS 217

Dear Sir:

A drawing showing proposed location of the emergency door identification label is enclosed. Paragraph S5.5.3 requires the designation "emergency door" or "emergency exit" as appropriate, in letters at least two inches high of a color that contrasts with its background, located at the top of or directly above the emergency exit on both inside and outside surfaces of the bus.

This decal would be placed on the inside surface of the glass but would be viewed from the outside. The lettering would be black on a solid white background.

Please review this and advise if this will meet requirements of Paragraph S5.5 of FMVSS 217.

E. M. Ryan, Chief Design Engineer

EMERGENCY DOOR

2" BLACK LETTERS ON WHITE BACKGROUND PRESSURE SINSITIVE DECAL

NOTE: DETAIL VIEW 1/4 SCALE

WARD

SCHOOL BUS MFG., INC. P.O. BOX 311 HIGHWAY 65 CONWAY, ARKANSAS 72032

OUTSIDE EMERGENCY DOOR DECAL LOCATION

DATE

CHK

DRAFT: (Illegible Word)

ENGR: SCALE N OR PART ORDER NO. REV CHANGE BY DATE ENGR (Illeg.) (Illeg.) PER BUS (Illeg.)

(Graphics omitted)

ID: nht78-3.23

DATE: 02/14/78

FROM: AUTHOR UNAVAILABLE; J. J. Levin, Jr.; NHTSA

TO: Collins Industries, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your November 15, 1977, letter asking several questions concerning Standard No. 217, Bus Window Retention and Release.

In your first question, you paraphrase the requirements of S5.3.3 concerning emergency exit force requirements and release motion and ask whether your understanding of the section is correct. Your interpretations of the standard's requirements are accurate.

Second, you enclosed photographs of a manufacturer's rear emergency door release mechanism and asked whether it complies with the standard's requirements. The force release mechanism shown in the pictures does not comply with the requirements of Standard No. 217. The release mechanism is not located in the high force access region as required by the standard, and the motion required for release of the exit is not upward as required by paragraph S5.3.3

Finally, you asked whether your enclosed copy of Standard No. 217 which includes paragraph S5.2.3.1 is up-to-date. The answer to your question is yes. You have been confused by paragraph S5.2.3.1 because it states that a bus must have, at a minimum, one rear emergency door or a side emergency door and a rear push-out window. The requirement for one rear emergency door does not preclude a schoolbus with a 10,000 pound GVWR or less from using two (double) rear emergency doors. Paragraph S5.4.2.2 states ". . . the opening of the rear emergency door or doors shall be . . ." (Emphasis added). The use of the term "doors" in paragraph S5.4.2.2 indicates that double doors are permitted.