Interpretation ID: nht93-8.27

DATE: November 22, 1993

FROM: Jane L. Dawson -- Specifications Engineer, Thomas Build Buses, Inc.

TO: Walter Myers -- Chief Counsel's Office, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 4/1/94 from John Womack to Jane L. Dawson (A42; Std. 217)

TEXT:

Last week I requested some clarification from you concerning the final rule to FMVSS 217, and you suggested that I fax you my questions. Please address the following:

1. The definition of "daylight opening" refers to the maximum unobstructed opening. What constitutes an obstruction and how close to the door does an object have to be in order to be considered an obstruction?

2. In the current rule, each school bus must be equipped with either a rear emergency door OR a LS emergency door in the rear half of the bus passenger compartment and a pushout rear window. Has the location of the INITIAL LS emergency door been changed so that it is now required to be as near as practicable to the midpoint of the passenger compartment or is the INITIAL LS emergency door still required to be in the rear half of the bus passenger compartment, and only a LS door that is used as an additional emergency exit required to be located as near as practicable to the midpoint of the passenger compartment?

Walter, I know that this will require a WRITTEN response from you, but I'd appreciate it if you would call me at (910) 841-5798 and go over it verbally before you write a response to save some time.