Interpretation ID: 1982-3.28

TYPE: Interpretation-NHTSA

DATE: December 7, 1982

FROM: Frank Berndt -- Chief Counsel

TO: M.B. Mathieson -- Director of Engineering, Thomas Built Buses Inc.

TITLE: None

ATTACHMT: Attached to letter dated 1-29-90 from C. Karl to M. Shaw (OCC 4403); Also attached to letter dated 1-18-90 from R.E. Meadows; Also attached to letter dated 1-8-90 from R. Marion to C. Karl; Also attached to memo dated 11-28-8? from C. Karl to All School Bus LCR II's; Also attached to letter dated 11-27-90 from P.J. Rice to C. Karl (A36; Std. 217)

TEXT:

This responds to your September 13, 1982, letter concerning your "vandalock" system and Standard No. 217, Bus Window Retention and Release.

Section S5.2.3.2 states that "the engine starting system of a school bus shall not operate if any emergency exit is locked from either inside or outside the bus. For purpose of this requirement, "locked" means that the release mechanism cannot be activated by a person at the door without a special device such as a key or special information such as a combination." You state that your locking mechanism, which is a bolt device, doesn't meet the definition of "locked" since it requires neither a key nor special instructions. You further indicate that the engine will not start until the bolt is withdrawn.

We disagree that your bolt when in the closed position would not meet the definition of locked. The door would not be capable of opening from the outside without the use of special devices when the bolt was closed. Accordingly, the door would be considered locked.

However, nothing in Standard No. 217 prohibits the installation of locking doors as long as the vehicle cannot be started with the door in the locked position. As you noted, your vandalock system is designed to prevent the starting of a vehicle in such circumstances.