Interpretation ID: nht94-3.8

TYPE: INTERPRETATION-NHTSA

DATE: May 26, 1994

FROM: Eric T. Stewart -- Engineering Manager

TO: Office of Chief Counsel -- NHTSA

TITLE: NONE

ATTACHMT: Attached to a letter dated 7/14/94 from John Womack to Eric T. Stewart (A42; STD 217)

TEXT: REFERENCE: Notice of proposed rule making, response to petition for reconsideration published in the Federal Register December 1, 1992 (Docket 88-21 notice No. 7) and Final rule; technical amendment to FMVSS 571.217 published in the Federal Register Dece mber 2, 1992 (Docket 88-21 notice No. 5)

The background to docket 88-21 notice no 7, Federal register page number 63324, states that "the agency believes that ALL existing exits should be subtracted before determining if additional exits will be required. The agency also notes that the front s ervice door of a non school bus can be counted as an emergency exit if it complies with the performance requirements in standard No. 217."

The above comment by NHTSA raises a question in the minds of the engineering personnel at Mid Bus, because we are currently in the process of designing a unique bus for the school and commercial bus market. This bus could have a capacity of 48 children or 40 adults. The chassis will use the chassis manufacturers cab that has an existing left hand drivers door. Can the daylight opening of this existing door to the left of the drivers seat be used in the calculations of required emergency exit area if it meets the performance requirements of standard No. 217?

I am requesting written clarification indicating how NHTSA interprets standard No. 217 with regard to this existing left hand exit. If you have any questions, please call me at (419) 221-2525.