nht75-4.39 | NHTSA

DATE: 11/14/75

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Blue Bird Body Company

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of September 23, 1975, in which you inquire whether the emergency exit decal installations shown in photographs enclosed with your letter comply with paragraphs S5.5.1 and S5.5.2 of Federal Motor Vehicle Safety Standard (FMVSS) No. 217, "Bus Window Retention and Release."

It appears from the photographs you provided that some of the emergency exit markings may not comply with some of the requirements specified in FMVSS No. 217. Our specific comments are listed below:

1. Figure 1 - The emergency exit marking for the rear door appears to meet the requirements. It is to be noted, however, that revised requirements for emergency exits on school buses have been proposed which may differ from the current requirements.

2. Figures 2 and 3 - The emergency exit marking for the side push-out windows does not appear to meet the requirements of S5.5.2. Both the seat back and the adjacent seated occupant partially obstruct the marking so it is not legible from the adjoining seat or the aisle location.

3. Figure 4 - The emergency exit marking for the side door appears to meet the requirements.

4. Figure 5 - The marking for the rear window emergency exit that is adjacent to a davenport type seat with unknown seating capacity appears to contain two release mechanisms (laterally spaced at each edge) and an identical marking for each latch mechanism. We cannot determine if occupants would obstruct these markings from standees if all positions in the davenport type seat were occupied.

We also question whether the instructions are complete because it cannot be determined if both latches must be released before the window can be pushed out.

5. Figure 6 - The emergency exit marking for the transit sliding type window appears to meet the requirements.

6. Figure 7 - The center rear emergency door which contains instructions for unlatching the opening of the door in the form of an arrow only per the proposed amendment to FMVSS No. 217, Docket 75-3: Notice 1 does not meet the present requirements for emergency exit identification. The specific content of the emergency exit marking for school buses has not yet been finalized by this agency and we, therefore, cannot comment until a final rule on the proposal has been published in the Federal Register.

7. Figures 8 and 9 - The emergency exit marking for another transit sliding type window appears to meet the requirements.

It is emphasized that these comments are for your information only and are based on the contents of your photographs. This agency cannot make a final judgment concerning compliance of a bus from photographs of components. The determination of compliance or noncompliance with FMVSS No. 217 can be made only by the actual inspection and test of a complete vehicle.

I trust this information will be of assistance to you in regard to your inquiries.

SINCERELY,

BLUE BIRD BODY COMPANY

September 23, 1975

Richard Dyson Assistant Chief Counsel U. S. Dept. of Transportation NHTSA

REFERENCE: (1) Letter from Francis Armstrong to Albert C. Luce, N41-21 MPa, CIR 1392 dated August 5, 1975

(2) Letter from W. G. Milby to Frank Burns (Berndt) dated August 11, 1975

As you know, reference (1) alleges non-compliance of the test vehicle with respect to FMVSS 217 in two areas:

1. The emergency exit signs do not contain concise operating instructions as required by S5.5.1.

2. The emergency exit signs are not legible to occupants seated in the adjoining seat or standing in the aisle location that is closest to the adjacent seat as required by S5.5.2.

While we do not agree with these allegations, we do wish that there be no question of our compliance with any NHTSA regulations as explained in reference (2).

Therefore, please find enclosed photographs of alternate emergency exit decals that we are proposing to use in lieu of the type used on the test bus of reference (1). In addition are proposed decals for other types of emergency exits. An explanation of each photo follows.

Figure 1 - Center rear emergency door same as on test bus of reference (1).

Figure 2 - Side pushout window same as on test bus of reference (1) with occupant in adjacent seat as viewed by standing occupant standing in aisle location that is closest to the adjacent seat.

Figure 3 - Same installation as in figure 2 but without occupant. Complete text of decal is:

"EMERGENCY EXIT TO OPEN PULL HANDLE - PUSH OUT WINDOW"

Figure 4 - Side emergency door with occupant in adjacent seat as viewed by occupant standing in aisle location that is closest to the adjacent seat.

Figure 5 - Center rear emergency window with occupant seated in adjacent davenport type seat.

Figure 6 - Transit sliding type window with pushout feature. Although not shown in photo, we would propose to use this decal on both panes of glass.

Figure 7 - Center rear emergency door same as on test bus of reference (1). As we understand it, arrow type decal is only operating instruction required by proposed amendment to FMVSS 217, Docket 75-3; Notice 1 as published in Federal Register of February 28, 1975. In addition, we understand this proposal would require an identification decal reading "EMERGENCY DOOR" both inside and outside immediately above the door in letters at least two inches high.

Figure 8 - Another transit sliding type window with pushout feature with occupant seated in adjacent seat as viewed by occupant standing in aisle location that is closest to the adjacent seat.

Figure 9 - Same as figure 8 but without seated occupant.

Please review each of these proposed decal installations and offer us an opinion whether or not they meet the requirements of FMVSS 217 regarding:

1. Concise operating instructions per S5.5.1.

2. Legibility per S5.5.2.

Your early response to this letter will be greatly appreciated so that we can make any necessary changes.

Thank you.

W. G. Milby Staff Engineer

(Graphics omitted)

Interpretation ID: nht75-4.39