Interpretation ID: nht76-5.7

DATE: 12/09/76

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Wayne Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of November 15, 1976, in which you ask whether emergency exits installed in school buses beyond those required in S5.2.3 of Standard No. 217, Bus Window Retention and Release, must meet the requirements of the standard.

The NHTSA has determined previously that only those exits required in S5.2.3 must meet the requirements specified for school bus emergency exits in Standard No. 217. All other emergency exits installed in school buses must comply with the requirements for emergency exits in buses other than school buses. These requirements are detailed in Standard No. 217.

In your letter, you ask specifically whether S5.2.3.1(b), S5.3.1, S5.3.2, S5.3.3, S5.4.1, S5.4.2.1(b), or S5.5.3 apply to a side emergency door in a school bus that already complies with S5.2.3.1(a) of the standard. The NHTSA concludes that this door would be required to comply with S5.3.1, S5.3.2, and S5.4.1 of the standard.

SINCERELY,

Wayne Corporation

November 15, 1976

Frank R. Berndt Office of Chief Counsel NHTSA

This inquiry is in reference to FMVSS 217, Bus Window Retention and Release, as applied to school buses with a GVWR of more than 10,000 pounds. In the case of a school bus equipped with a side emergency door, in addition to a rear emergency door furnished in compliance with the requirements of Sections S5.2.3.1(a), S5.3.3, S5.4.2.1(a) and S5.5.3, which if any of the following requirements must the side door comply with:

S5.2.3.1(b), S5.3.1, S5.3.2, S5.3.3, S5.4.1, S5.4.2.1(b) or S5.5.3?

Your prompt attention to this matter and an early reply will be greatly appreciated.

Robert B. Kurre Director of Engineering