Interpretation ID: nht76-5.9

DATE: 05/28/76

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Truck Body and Equipment Association, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This responds to the Truck Body Equipment Association's May 7, 1976, question whether S5.2.3.2 of Standard No. 217, Bus Window Retention and Release, requires that the engine starting system of a school bus not operate if an emergency exist other than an emergency door is locked. Section S5.2.3.2 applies to school buses manufactured on or after October 26, 1976.

Section S5.2.3.2 only specifies requirements for the relationship of the engine-starting system to the operation of emergency doors. Reference to "any emergency exit" in the first sentence of the section is in error, as the correct reference to "emergency door" in the second sentence of the section demonstrates. A correction of this error will be made in the text of the standard shortly.

SINCERELY,

TRUCK BODY AND EQUIPMENT ASSOCIATION, (Illegible Word)

May 7, 1976

Frank Berndt, Acting Chief Counsel NHTSA

A question concerning FMVSS 217 as it relates to "School Bus Emergency Exit Requirements" was discussed at our recent Engineering Meeting. Section S5.2.3.2 states:

"The engine starting system of a school bus shall not operate if any emergency exist is locked from either inside or outside the bus. For purposes of this requirement, 'locked' means that the release mechanism cannot be activated by a person at the door without a special device such as a key or special information such as a combination."

Our question concerns the use of the term "emergency exits" in this section with regards to the ignition interlock system.

Does this section require the installation of an ignition interlock system on push-out type emergency windows?

Thanking you in advance for your prompt reply.

Byron A. Crampton Manager of Engineering Services