Interpretation ID: 1982-2.19

DATE: 07/06/82

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Truck Body & Equipment Association -- Bradley Sweet

TITLE: FMVSS Interpretation

TEXT:

Truck Body & Equipment Association 5530 Wisconsin Avenue, Suite 1220 Chevy Chase Maryland 20815

Dear Mr. Sweet:

Since you represent the School Bus Manufacturers Institute, I am writing for your assistance. We are reinterpreting the requirements of @5.3.3 of Standard No. 217. Bus Window Retention and Release, as they apply to audible warning devices and would like your assistance in disseminating this interpretation.

As you know, the standard requires that a continuous warning sound shall be audible at both the driver's seating location and in the vicinity of the enclosed door. In the preamble to the notice implementing this requirement, the agency stated that section @5.3.3 requires two warning devices one located at each position. The agency made this interpretation based upon the then available data indicating that a single warning device in a bus might not be audible in both locations.

In the years that this requirement of the standard has been in effect, the agency has reexamined the issue in light of experience and finds that it is possible to have only one warning device audible at both locations. We have determined that this device can be heard even when a bus is loaded with noisy children. In accordance with this finding, the agency is reinterpreting the language of section @5.3.3 to permit one warning device is that device is audible at both locations. We caution manufacturers to ensure that their warning devices will be audible at both locations even when the bus is loaded.

Thank you for your assistance in providing this information to your members and others in the school bus industry.

Sincerely,

Frank Berndt Chief Counsel