Interpretation ID: nht79-2.34

DATE: 02/02/79

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

TO: United Bus Sales, Inc.

TITLE: FMVSS INTERPRETATION

TEXT:

FEB 2 1979

NOA-30

Mr. Melvin Ives President United Bus Sales, Inc. 6700 S. Garfield Avenue Bell Gardens, California 90201

Dear Mr. Ives:

This responds to your November 6, 1978, letter asking for an interpretation of the warning buzzer requirement of Standard No. 217, Bus Window Retention and Release.

The standard requires a warning buzzer to sound when an emergency door release mechanism is not in the closed position and the vehicle's ignition is on. From conversations with you and our Office of Vehicle Safety Compliance, we have determined that your rear emergency door uses a warning buzzer that sounds when the door release mechanism is not in the closed position unless someone continues to exert pressure to hold the door closed. The National Highway Traffic Safety Administration considers such a warning device to be in compliance with the standard. The purpose of the warning alarm is to warn passengers and the driver when a door is accidentally left in the open condition while the vehicle ignition is in the on position. Your device appears to meet the intent of the standard.

We have discussed this issue with Mr. Jerry Alexander of the California Highway Patrol, and he has indicated that he will accept our determination. We are sending him a copy of this letter for his information.

Sincerely,

Joseph J. Levin, Jr. Chief Counsel cc: Mr. Jerry Alexander P.O. Box 11730 Fresno, California 93775

November 6, 1978

National Highway Traffic Safety Administration 400 West 7th Street Southwest Washington, D.C. 20590

Attention: Chief Counsel

Gentlemen:

It has been suggested by the Commercial Vehicle Section of the Highway Patrol, State of California, that we ask you for a legal interpertation of Federal Standard, Part 571; S-217, Section S5.3.3 (C) pertaining to the position of the release mechanism and the sounding of the warning buzzer.

Specifically:

"When the release mechanism is not in the closed position, and the vehicle ignition is in the "on" position, a continuous warning sound shall be audible--------."

It is our feeling that our van-type school buses comply. It would, however, be most helpful if we could have an interpretation of the above quoted section for clarification. Mr. George Shifflett, your Compliance Specialist, has visited our plant and is familiar with the details of our units and our request and has been most helpful to us.

Sincerely,

UNITED BUS SALES, INC.

Melvin Ives President

MV/daw

cc: Zemaitis, Joseph Shifflett, George Campoy, Cliff Canova, Andy 02/02/79