Interpretation ID: CORRECTN.PJA

Mr. Thomas D. Turner
Manager, Engineering Services
Blue Bird Body Company
P.O. Box 937
Fort Valley, Georgia 31030

Dear Mr. Turner:

This follows up on our March 20, 1996, interpretation letter regarding Federal Motor Vehicle Safety Standard (FMVSS) No. 217, Bus emergency exits and window retention and release. That letter contained an error, which was explained to you by Paul Atelsek of my staff in a telephone conversation.

In response to your first question, we stated that the voluntarily installed side exit doors would still be subject to prohibitions and requirements that apply to side exit doors generally. That is true. However, we went on to give two examples of prohibitions and requirements in section S5.2.3.2. As the enclosed letter to Ms. Jane Dawson of Thomas Built Buses explains, that section has an introductory sentence that, contrary to the agency's intent, restricts the scope of the requirements to required exit doors.

We would also like to correct any possible implication that voluntarily installed exits are not subject to some requirements. The sentence at the top of page 2 of the March 20 letter stated "[t]o avoid confusion, the force and motion needed to open the [voluntarily installed] exit should be consistent with the other emergency exits (emphasis added)." In fact, the force and motion requirements of S5.3.3 apply to "each" exit, which includes voluntarily installed exits.

We apologize for the error. If you have any questions, feel free to contact Paul Atelsek of my staff at 202-366-5260.

Sincerely,



Samuel J. Dubbin
Chief Counsel

Enclosure
ref:217
d:8/1/96