Interpretation ID: aiam3511
Truck Body & Equipment Association
5530 Wisconsin Avenue
Suite 1220
Chevy Chase
MD 20815;
Dear Mr. Sweet: Since you represent the School Bus Manufacturers Institute, I a writing for your assistance. We are reinterpreting the requirements of S5.3.3 of Standard No. 217, *Bus Window Retention and Release*, as they apply to audible warning devices and would like your assistance in disseminating this interpretation.; As you know, the standard requires that a continuous warning soun shall be audible at both the driver's seating location and in the vicinity of the unclosed door. In the preamble to the notice implementing this requirement, the agency stated that section S5.3.3 requires two warning devices, one located at each position. The agency made this interpretation based upon the then available data indicating that a single warning device in a bus might not be audible in both locations.; In the years that this requirement of the standard has been in effect the agency has reexamined the issue in light of experience and finds that it is possible to have only one warning device audible at both locations. We have determined that this device can be heard even when a bus is loaded with noisy children. In accordance with this finding, the agency is reinterpreting the language of section S5.3.3 to permit one warning device if that device is audible at both locations. We caution manufacturers to ensure that their warning devices will be audible at both locations even when the bus is loaded.; Thank you for your assistance in providing this information to you members and others in the school bus industry.; Sincerely, Frank Berndt, Chief Counsel