Interpretation ID: aiam4014
Supervisor
Technical Support
Room 28
New York City Transit Authority
25 Jamaica Avenue
Brooklyn
NY 11207;
Dear Mr. Gomes: This responds to your June 21, 1985 letter to this office concernin our requirements for emergency exits under Federal Motor Vehicle Safety Standard No. 217, *Bus Window Retention and Release*. I apologize for the delay in our response.; In a July 15 telephone conversation with Ms. Hom of my staff, yo explained that your question concerns the side rear door on transit buses which is used to unload passengers. The door in question is not intended as an emergency exit, and the buses have the requisite emergency exits in compliance with Standard No. 217 without the need to count the rear exit door. Typically, passengers can exit the bus by pushing handles which open the door, after the driver activates a mechanism located in the driver's compartment. The Transit Authority would like to place another activating mechanism near the rear exit door that can be operated 'in an emergency.' You propose to place the second mechanism in a 'break-away' plastic case and ask whether we have standards specifying requirements for materials used for that purpose.; There are no safety standards setting requirements for the material yo wish to use to cover the secondary release mechanism. Your questions, however, raises the issue of the applicability of Standard No. 217's emergency exit requirements to the rear exit door. This question arises in cases where a label is attached to a door indicating that it is to be used in an emergency.; From your description, it appears that a label would be attached to th mechanism at the rear door instructing passengers how to open the door in an emergency.; We have stated in the past that a door that is not labeled or intende as an emergency exit need not comply with the emergency exit requirements of Standard No. 217. However, if a door were labeled with instructions on how to open the door in case of an emergency, such as 'To Open Door In Emergency Pull Down,' then the label indicates that the door is intended for use as an emergency exit. Such a door must comply with the requirements applicable to emergency doors in Standard No. 217, since the label indicates to the occupants that the door is suitable for use in an emergency and it is likely that riders would use the door as an emergency exit. The National Highway Traffic Safety Administration has uniformly required this of all doors labeled with instructions for use in emergencies.; One purpose of Standard No. 217 is to provide a means of readil accessible emergency egress. While the standard does not explicitly prohibit a plastic case around an emergency exit release mechanism, it is obvious that any type of design or device which would inhibit the release of the mechanism would not be allowed. We urge you to ensure that the release mechanism is easily accessible to bus occupants and that the plastic case does not unnecessarily impede its operation.; Under the National Traffic and Motor Vehicle Safety Act of 1966 (1 U.S.C. 1381 *et seq.), manufacturers of new motor vehicles and motor vehicle equipment must certify that their products conform to all applicable Federal motor vehicle safety standards. Any person selling you a new bus with the rear exit door marked as an emergency exit must ensure that the door meets Standard No. 217's requirements for emergency exits. The Transit Authority may modify its buses by labeling the rear exit door with instructions for use in an emergency after it receives delivery of the vehicles without regard to our safety standards, since our authority under the Vehicle Safety Act does not extend to the use of vehicles by their owners. However, we would urge the Transit Authority to carefully consider the benefits of assuring continued compliance with all applicable motor vehicle safety standards.; I hope this information is helpful. Please contact this office if yo have further questions.; Sincerely, Jeffrey R. Miller, Chief Counsel