Interpretation ID: nht90-1.13

TYPE: INTERPRETATION-NHTSA

DATE: 01/09/90

FROM: STEPHEN P. WOOD -- NHTSA ACTING CHIEF COUNSEL

TO: JAMES A. COWAN, DIRECTOR OF ENGINEERING CROWN COACH INCORPORATED

TITLE: NONE

ATTACHMT: LETTER DATED 11/24/89 FROM JAMES A. COWAN -- CROWN COACH INC TO ERIKA JONES -- NHTSA; RE FMVSS 217, BUS WINDOW RETENTION AND RELEASE; OCC 2847; LETTER DATED 11/29/88 FROM JAMES A. COWAN -- CROWN COACH INC; RE FMVSS 217, BUS WINDOW RETENTION AND RELEASE

TEXT: Dear Mr. Cowan:

This is in response to your request for an interpretation of Federal Motor Vehicle Safety Standard No. 217: Bus Window Retention and Release. I apologize for the delay in responding to your inquiry.

Your letter explained that Crown plans to sell one prototype school bus model which was developed but not produced, and which contains a side emergency exit which is wider than required under Standard No. 217. Because of the wider door, the seatback of the passenger seat located immediately forward of the emergency exit door intrudes into the emergency door exit opening. You have requested an interpretation as to whether this is consistent with Standard No. 217. The answer to your question is no.

Standard No. 217 specifically requires that "[a] vertical transverse plane tangent to the rearmost point of a seatback shall pass through the forward edge of a side emergency door." S5.4.2.1(b). This requirement prohibits the forward seat or seatback fr om extending into the door opening regardless of the size of the door opening. Therefore, as it is now configured, the bus you have described in your letter is not in compliance with Standard No. 217.

I hope you have found this information helpful. Please contact David Greenburg of this office at (202) 366-2992 if you have any further questions concerning this issue.

Sincerely,