Interpretation ID: nht78-3.27

DATE: 02/14/78

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

TO: Ward Industries, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your December 14, 1977, letter asking whether the rear push out window emergency exit option in Standard No. 217, Bus Window Retention and Release, is limited to rear-engine school buses.

The National Highway Traffic Safety Administration (NHTSA) initially proposed that this option be restricted to rear-engine school buses. Comments to that rulemaking, however, persuaded the agency to permit the use of these emergency exits on all school buses regardless of the location of the engine or passenger seats. That determination was explained in the preamble to the final rule published on June 3, 1976 (41 FR 22356) (enclosed).

I trust that this fully responds to your question.

SINCERELY,

WARD Industries, Inc.

December 14, 1977

Joseph Levin, Chief Office of Chief Counsil National Highway Traffic Safety Admn.

Re: FMVSS 217

Dear Mr. Levin:

Paragraph S5.2.3.1(b) and referenced Figure 3C of FMVSS 217 permits the use, as a manufacturer's option, one emergency door on the vehicle left side and a pushout rear window (16 inches x 48 inches).

Does this standard permit the use of this rear window in other than rear engine type vehicles? We have had requests from schools to manufacture a conventional school bus equipped with the above combination of emergency exits.

Since Figure 3C of referenced FMVSS shows a rear shelf between the rear seat and the rear wall, does this prohibit the use of the rear pushout window when seats are located all the way to the rear wall?

An early response to this petition for clarification will be appreciated.

E. M. Ryan, Chief Design Engineer

cc: BUD RYAN; JAMES STRAUB