Interpretation ID: nht78-3.23

DATE: 02/14/78

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

TO: Collins Industries, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your November 15, 1977, letter asking several questions concerning Standard No. 217, Bus Window Retention and Release.

In your first question, you paraphrase the requirements of S5.3.3 concerning emergency exit force requirements and release motion and ask whether your understanding of the section is correct. Your interpretations of the standard's requirements are accurate.

Second, you enclosed photographs of a manufacturer's rear emergency door release mechanism and asked whether it complies with the standard's requirements. The force release mechanism shown in the pictures does not comply with the requirements of Standard No. 217. The release mechanism is not located in the high force access region as required by the standard, and the motion required for release of the exit is not upward as required by paragraph S5.3.3

Finally, you asked whether your enclosed copy of Standard No. 217 which includes paragraph S5.2.3.1 is up-to-date. The answer to your question is yes. You have been confused by paragraph S5.2.3.1 because it states that a bus must have, at a minimum, one rear emergency door or a side emergency door and a rear push-out window. The requirement for one rear emergency door does not preclude a schoolbus with a 10,000 pound GVWR or less from using two (double) rear emergency doors. Paragraph S5.4.2.2 states ". . . the opening of the rear emergency door or doors shall be . . ." (Emphasis added). The use of the term "doors" in paragraph S5.4.2.2 indicates that double doors are permitted.