Interpretation ID: nht79-3.50

DATE: 07/06/79

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Wayne Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your June 11, 1979, letter asking whether side push-out window exits in school buses installed pursuant to State requirements must be marked in accordance with the emergency exit requirements of S5.5.3 of Standard No. 217, Bus Window Retention and Release. In particular, you want to know whether these additional exits must be labeled on the bus exterior.

Section S5.5.3 of the standard requires that "[each] school bus emergency exit provided in accordance with S5.2.3.1 shall have the designation . . . . on both the inside and outside surfaces of the bus. Section S5.2.3.1, in turn, requires that school buses be equipped with a rear emergency door or a side emergency door and a rear push-out window. Taken together, these two sections require that the required rear or side emergency door or rear push-out window must be appropriately marked on the inside and outside of the bus.

As the agency has frequently stated, all exists installed in school buses beyond those required by S5.2.3.1 need not comply with the exit requirements applicable to school bus exits. All additional exists must comply, however, with the other sections of the standard applicable to non-school buses. In this case, the additional exits would be required to be labeled in accordance with Sections S5.5.1 and S5.5.2 of the standard. Neither of these paragraphs requires the exit to be marked on the bus exterior.

SINCERELY,

Wayne Corporation

June 11, 1979

Frank Berndt Chief Counsel U.S. Department of Transportation % National Highway Traffic Safety Administration

Dear Mr. Berndt:

The State of New York Department of Transportation has raised a question concerning the exterior labeling of side push-out windows in school buses. Specifically, they maintain that Section S5.5.3 of FMVSS 217 requires that side emergency push-out windows specified in the New York school bus standard be labeled on the outside of the bus as specified in this section. Wayne maintains that only the rear emergency door, side emergency doors, and rear push-out windows are required to be labeled on the exterior in accordance with the requirements of S5.5.3.

Please advise which of these interpretations is correct. Would you please send a copy of your reply to Mr. Martin Chauvin at the following address.

Mr. Martin V. Chauvin, Chief Carrier Safety Bureau New York State Department of Transportation 1220 Washington Avenue State Campus Albany, New York 12232

Robert B. Kurre Director of Engineering

CC: MARTIN CHAUVIN