Interpretation ID: 21866.drn
Monsieur Jean-Yves Le Bouthillier
Standards Manager
Les Entreprises Michel Corbeil Inc.
304 12th Avenue
Laurentides, Quebec JOR 1C0
CANADA
Dear Monsieur Le Bouthillier:
This responds to your request for an interpretation of whether the interior emergency exit designation on a school bus exit door may be placed on the top half of the emergency exit door. The answer is yes.
With your submission, you provided a photograph (which you call Picture 483) of the rear interior of a Corbeil school bus. In the vehicle's interior, a large piece of equipment (described in your submission as the air conditioning unit) entirely covers the area (in both length and width) above the emergency door, and under the interior roof. On the top half of the emergency exit door, on the glazing, is the designation "Emergency Exit." You write that because of the air conditioning unit's location, the interior emergency exit door designation cannot be placed above the door. You therefore propose the top half of the emergency exit door for the interior "Emergency Exit" designation.
Among other requirements, Standard No. 217, Bus emergency exits and window retention and release, specifies at S5.5.3(a) that each school bus emergency exit provided in accordance with S5.2.3.1 shall have the designation "Emergency Door" or "Emergency Exit," and that the designation shall be located at the top of, or directly above, the emergency exit door on both the inside and outside surfaces of the bus.
The National Highway Traffic Safety Administration (NHTSA) has addressed your question in a letter of September 28, 1977, to Thomas Built Buses, Inc. (copy provided). In that letter, NHTSA interpreted the emergency exit door designation requirement "to mean that the emergency door label must be located on the top half of the door or directly above the door."
Your Picture 483 shows the interior "Emergency Exit" designation to be placed on the door's glazing, on the top half of the door. Since the designation is located on the top half of the door, a school bus with the designation placed in the depicted location would meet S5.5.3(a) of Standard No. 217.
I note that S5.5.3(a) specifies that the designation be placed "on both the inside and outside surfaces of the bus." Since your designation is on the emergency exit door's glazing, you may be interested in the enclosed letter of October 2, 1987, to Ward Industries, Inc., in which NHTSA determined that a school bus with an interior label placed on the emergency exit door's glazing that is visible from the outside of the school bus meets exterior and interior placement requirements. The words "Emergency Exit" or "Emergency Door" must be readable (not backwards) when viewed from inside the school bus and from outside of the school bus.
I hope this information is helpful. If you have any further questions, please feel free to contact Dorothy Nakama of my staff at this address or at (202) 366-2992.
Sincerely,
Frank Seales, Jr.
Chief Counsel
Enclosures
ref.217
d.8/11/00