Interpretation ID: nht78-3.22

DATE: 10/02/78

FROM: AUTHOR UNAVAILABLE; J. J. Levin, Jr.; NHTSA

TO: Ward Industries, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your August 22, 1978, letter asking whether your proposed emergency door label complies with the requirements of Standard No. 217, Bus Window Retention and Release.

Paragraph S5.5.3 requires that each school bus emergency exit shall have the designation "Emergency Exit" or "Emergency Door" as appropriate, in letters at least 2 inches high, of a color that contrasts with its background, located at the top of or directly above the emergency exit on both the inside and outside surfaces of the bus. The label that you propose would be located on the inside of the glass but would be visible from the outside of the vehicle.

The National Highway Traffic Safety Administration (NHTSA) has indicated in the past that the location of the emergency exit label can be directly above or on the top half of the emergency exit. Your location near the top of the glass on the rear emergency door appears to fall within this acceptable area. The standard further requires that the label be located on both the inside and outside surfaces of the bus. The intent of this requirement is to provide a visible emergency exit designation on both the inside and outside of a bus. Since your label would be visible outside the school bus even though its location would be on the inside of the glass, the NHTSA concludes that it complies with this requirement. In reaching this conclusion, the agency assumes that you will have a similar label that will be visible inside the bus.

In summary, since your described label is the required size, consists of contrasting colors, and is placed in the appropriate location, it appears to comply with the requirements of Standard No. 217.

SINCERELY,

WARD Industries Inc.

August 22, 1978

Joseph J. Levin, Jr. Chief Counsel National Highway Traffic Safety Admn.

Ref: FMVSS 217

Dear Sir:

A drawing showing proposed location of the emergency door identification label is enclosed. Paragraph S5.5.3 requires the designation "emergency door" or "emergency exit" as appropriate, in letters at least two inches high of a color that contrasts with its background, located at the top of or directly above the emergency exit on both inside and outside surfaces of the bus.

This decal would be placed on the inside surface of the glass but would be viewed from the outside. The lettering would be black on a solid white background.

Please review this and advise if this will meet requirements of Paragraph S5.5 of FMVSS 217.

E. M. Ryan, Chief Design Engineer

EMERGENCY DOOR

2" BLACK LETTERS ON WHITE BACKGROUND PRESSURE SINSITIVE DECAL

NOTE: DETAIL VIEW 1/4 SCALE

WARD

SCHOOL BUS MFG., INC. P.O. BOX 311 HIGHWAY 65 CONWAY, ARKANSAS 72032

OUTSIDE EMERGENCY DOOR DECAL LOCATION

DATE

CHK

DRAFT: (Illegible Word)

ENGR: SCALE N OR PART ORDER NO. REV CHANGE BY DATE ENGR (Illeg.) (Illeg.) PER BUS (Illeg.)

(Graphics omitted)