Interpretation ID: nht75-4.37

DATE: 06/26/75

FROM: AUTHOR UNAVAILABLE; R. L. Carter; NHTSA

TO: Department of Public Instruction - Delaware

TITLE: FMVSS INTERPRETATION

TEXT: This letter is in further response to your phone call to Mr. David Soule, concerning the proper wording of captions above emergency doors and/or exits in school buses.

While we do not consider the phrase "Emergency Door" to be synonymous with "Emergency Exit" (we do not believe push-out windows or other nondoor emergency exits are appropriately marked "Emergency Door"), we would not consider a bus failing to conform to Standard No. 217, Bus Window Retention and Release, if its emergency doors were marked "Emergency Door." Emergency exits other than doors, however, must be marked "Emergency exit." National Highway Traffic Safety Administration standards apply only to vehicles manufactured after a standard's effective date. Standard No. 217 does not apply to buses in use that were manufactured before its effective date of September 1, 1973.

I might point out that a Federal Register notice published February 26, 1975, proposing requirements for emergency doors in school buses would require that such exits be designated "Emergency Door."