Interpretation ID: nht78-4.27

DATE: 03/10/78

FROM: JAMES TYDINGS, -- THOMAS BUILT BUSES, SPECIFICATIONS ENGINEER

TO: ROGER TILTON -- U. S. DEPARTMENT OF TRANSPORTATION

TITLE: FMVSS #217 - SECTION 5.2, "PROVISION OF EMERGENCY EXITS".

ATTACHMT: ATTACHED TO LETTER DATED 02/03/88 FROM ERIKA Z JONES TO L.T. MITCHELL; REDBOOK A31, VSA 102, SEC 571 DEFINITION; STANDARD 208, 222; LETTER DATED 08/21/87 FROM L. T. MITCHELL TO ERIKA Z. JONES RE REQUEST FOR INTERPRETATION ON FMVSS 222 ON SCHOOL BUSES WITH GVWR OF 10,000 POUNDS OR LESS; OCC-945; LETTER DATED 05/11/78 FROM JOSEPH J. LEVIN TO JAMES TYDINGS

TEXT: Dear Mr. Tilton;

Confirming our phone conversation of March 10, 1978, regarding the above Standard and Section.

Our question revolved around the number of openings (Push-Out Windows) for a bus with wide seats (39" width) for adults.

The case we cited was that the 39" seat would be used by only two adults per seat. This was for comfort reasons. Yet in reading the definition of a "Designated Seating Position" where it speaks to "at least as large as a fifth percentile adult female", the seat could provide for three females of the above size or smaller.

Our contention was that our intent and that of the user was that the seat would be occupied by only two adults, and we would base our calculations upon that number to establish the number of exits.

It was further discussed that there would be no intent on our part tothe safety provisions of the standard.

We also suggested that we would label the vehicle seating capacity on insidevehicle in plain sight. To this you agreed, stating that it would be

Trusting this is an accurate record of conversation, we shall look forward to concurrence in this matter.