Interpretation ID: nht76-5.8

DATE: 12/03/76

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Blue Bird Body Company

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of November 3, 1976, in which you ask whether the label "Emergency Door," when placed on the glass near the top of a school bus emergency exit, complies with the requirements of Standard No. 217, Bus Window Retention and Release.

The positioning of this label will be regulated by S5.5.3 of Standard No. 217 in the case of school buses manufactured on or after April 1, 1977. That section, as it pertains to the location of the designation "Emergency Door," states in part that the designation shall be ". . .located at the top of or directly above the emergency exit. . ." The markings you describe, located at the top of the glass of the emergency door, would appear to be in compliance with the location requirements of S5.5.3 of Standard No. 217 (effective April 1, 1977).

SINCERELY,

BLUE BIRD BODY COMPANY

November 3, 1976

Frank Berndt Acting Chief Counsel National Highway Traffic Safety Administration

SUBJECT: EMERGENCY DOOR MARKING - FMVSS 217

We are considering a change in early 1977 to a double faced decal made of 3 mil Mylar with a pressure sensitive adhesive which would be applied to the upper inside of the emergency door glass as shown in the enclosed photograph reproductions. We plan to use the designation "EMERGENCY DOOR" two inches in height with black letters on a metallic silver background. We would like to make a location change at the same time.

This type application would be visible from the inside and outside and, of course, would be protected from the weather because of inside application. The viewing angle for a person standing on the ground would be much improved since the decal would be 8" lower than if applied on the header above the emergency door.

Since we need to make a decision as soon as possible, we would appreciate a ruling on whether the above proposal meets FMVSS 217 section S5.5.3 at your earliest convenience.

Thanks

W. G. Milby Manager, Engineering Services Interior

Exterior

(Graphic omitted)