Interpretation ID: nht78-3.3

DATE: 09/13/78

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

TO: Department of Transportation - Rhode Island

TITLE: FMVSS INTERPRETATION

TEXT: I regret the delay in answering your letter. This responds to your questions concerning the recent amendment of Safety Standard No. 205, Glazing Materials, that permits the use of rigid plastics in the side windows of buses. Specifically, you ask whether the amendment includes school buses and whether plastic glazing would be allowed in entrance doors and in rear emergency doors of school buses.

Safety Standard No. 205 was amended to permit the use of rigid plastic glazing in all doors and windows of buses, except windshields or in windows to the immediate right or left of the driver (42 FR 61465, December 5, 1977). This amendment is applicable to school buses, since they are a special sub-category of "bus." The plastic glazing would not be allowed in a bus entrance door since this would constitute a "window to the immediate right" of the driver. Plastic glazing would be allowed in the rear emergency door, however, since that location was not excepted in the amendment.

Please contact Hugh Oates of this office if you have any further questions (202-426-2992).

Sincerely,

ATTACH.

STATE OF RHODE ISLAND AND PROVIDENCE PLANTATIONS

Department of Transportation

July 12, 1976

Joseph J. Levine -- Chief Counsel, N.H.T.S.A.

RE: Docket No. 71-1; Notice 06 Final Rule, Glazing Materials. Amended Safety Standard No. 205

Dear Sir:

During a recent telephone conversation with Ms. Nancy Egar it was suggested that I submit my request for an interpretation of the above mentioned amendment relative to glazing material to be used with the use of school buses.

In preparing our school bus inspection for the start of the September 1978 school year, I am in need of guidelines in interpreting whether or not rigid plastic glazing material is allowed for use in the school buses in particular locations such as the rear emergency door which is a visible location via the rear view mirror and the entrance door which is a visible location for children prior to the door being opened. Further to this, the overall amendment includes buses but I was wondering if school buses per say may be exempt in the interpretation of the word bus.

I would appreciate your reviewing the above comments and notifying me in writing as to the N.H.T.S.A. interpretation relative to these questions as soon as possible so that I in turn may respond to the school bus owners before August 15, 1978.

Sincerely yours, Alfred Massarone, Chief -- MOTOR VEHICLE SAFETY AND EMISSION CONTROL DIVISION