Interpretation ID: nht73-4.35

DATE: 06/28/73

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Crown Coach Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of June 1, 1973, concerning Standard No. 217, "Bus Window Retention and Release." You raise two questions regarding the standard: the first concerns the incompatibility of the standard with buses designed to transport convicts or other persons under physical restraint; the second, the possibility that the standard may preclude the use of a push-button release mechanism for emergency exits which you apparently presently use in many buses you manufacture.

We have received other communications regarding the incompatibility of Standard No. 217 with buses designed to transport convicts and are presently considering requests that these buses be exempted from the standard.

With respect to the use of push-button emergency exit release mechanisms, Standard No. 217 does not specify the design of emergency exit release mechanisms but, rather, specifies requirements which these release mechanisms, regardless of design, are required to meet. These requirements essentially specify the magnitude and direction of release forces necessary to operate the emergency exit release mechanism. If these requirements do preclude the use of a push-button release mechanism you wish to use, the appropriate procedure for you to follow is to petition for rulemaking to amend the standard, in accordance with NHTSA regulations (49 CFR @@ 553.31 et seq., copy enclosed). We recommend that you include detailed information on the type of release you wish to use as part of any such petition.

ENC.

Crown COACH CORPORATION

June 1, 1973

U. S. Department of Transportation National Highway Traffic Safety Admin.

Attention Office of Legal Counsel

We at Crown Coach Corporation are currently in the process of bidding on several bus units for GSA for the Atomic Energy Commission. We also are in the process of working on future bids for Los Angeles County Sheriff's Department, and the California State Department of Corrections. Some of these vehicles must have maximum security as they transport people who are dangerous criminals and we are of the belief that an exemption should be granted on Motor Vehicle Standard #217. If we are forced to comply with this Standard, we may as well not install any security measures on the vehicles because with the least effort all the prisoners would push out the side windows and escape.

We have been building maximum security vehicles for approximately 18 to 20 years, and last year we delivered our first two units to the U. S. Government.

We currently have two maximum security vehicles approximately four to five weeks away from completion for the U. S. Bureau of Prisons.

Our question would be can we consider these maximum security vehicles as exceptions, as they are not being used as a passenger bus in the true sense of the word in that they are not transporting people for hire. It is my understand from communications that we have had with GSA, at our request, several weeks ago that this question was put before you people in regard to the above questions.

A further question. There are several manufacturers of buses, including Crown, who use bus sash that are not push-out type sash. This type is not mentioned in #217. We currently are producing buses with this type sash for the Federal Government, and for sightseeing purposes and charter use for use within the United States, including Alaska and the Hawaiian Islands. We are using large fixed by-pass sash where we exceed the number of square inches escape opening as set forth in Standard #217, Section S5.2 "Provision of Emergency Exits".

2

Our by-pass sash have an emergency button that is operated to obtain the required increased emergency exit opening at each window. We have three different sizes of sash, depending on the customer's requirements, all of which exceed your requirements in S5.2 for emergency exits opening without the kickout feature.

We would like to request your opinion on the above questions and if we are not clear we would be more than pleased to answer any questions you have and send photographs or drawings showing the type of product that we are talking about, and the individual items upon request.

We will be looking forward to an early reply to the above as this affects a current bid for a considerable number of buses for the U. S. Government, and can also mean further savings to the U. S. Government on maximum security vehicles and other types.

Kay Partman Vice President-Engineering