Interpretation ID: nht78-3.26

DATE: 02/14/78

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

TO: Thomas Built Buses

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your December 8, 1977, letter asking for an interpretation of the term "passenger compartment" as used by the National Highway Traffic Safety Administration (NHTSA) in Standard No. 217, Bus Window Retention and Release.

Standard No. 217 requires that a school bus side emergency door be located in the rear half of the bus passenger compartment. The NHTSA interprets the term "passenger compartment" to mean the area from the windshield to the back of the bus.

In a companion question, you ask whether it would be permissible for a small portion of a side emergency door, installed pursuant to S5.2.3.1(b), to fall within the front half of a bus as long as most of the door is within the required rear half of the passenger compartment. The answer to your question is no. The emergency door must be totally located within the rear half of the passenger compartment.

SINCERELY,

THOMAS BUILT BUSES, INC.

December 8, 1977

Office of the Chief Counsel U.S. Department of Transportation

Attn: Roger Tilton

Subject: School Buses - Emergency Door, Location of

Re: Federal Motor Vehicle Safety Standard 217, Bus Window Retention and Release, Section S5.2.3.1(b)

The above referenced section states: "One emergency door on the vehicle's left side that is in the rear half of the bus passenger compartment . . . .etc."

Several questions have arisen regarding the quoted portion of the standard, and we would appreciate an answer to these questions. We have included prints to help explain our inquiries.

1. Passenger Compartment: From what point to what point longitudinally is the passenger compartment measured? As can be seen on the print the passenger compartment may vary depending on what is definition of the passenger compartment.

Is it from the windshield to the rear of the bus (1/2L + 1/2L), or from the back of the front barrier to the rear of the bus? (1/2R + 1/2R) NOTE: For clarity, we have shown these measurements on opposite sides of the bus. Also for your information the State of New York measures (1/2L + 1/2L) or glass to glass as it is commonly called.

Our prime purpose of the inquiry is that the State of Washington requires that the side emergency door be located in front of the rear axle. In certain cases this is impossible, and still meet your requirement of FMVSS 217-S5.2.3.1(b). We realize that Federal Standards take precedent over the State Standard yet on certain models, due to the module construction, a portion of the door impinges upon the forward section of the passenger compartment. Is this permissible?

Areas marked W/H are wheelhouses, and no side emergency door may be installed in these area and comply with FMVSS 217-S5.4.2.1.(b).

If we may be of further assistance, kindly advise.

James Tydings, Specifications Engineer