Interpretation ID: nht79-3.46

DATE: 06/18/79

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Thomas Built Buses, Inc.

TITLE: FMVSS INTERPREATION

TEXT: This responds to your May 21, 1979, letter confirming your discussions with Roger Tilton of my staff relating to the emergency exit requirements of school buses that are constructed with an additional exit door. The additional door is installed so that the vehicle can be better used as a general transit vehicle when not in use for school purposes.

The statements that you make in your letter are, for the most part, accurate. However, your third statement which indicates that the additional door could not be marked as an emergency exit is not entirely accurate. Additional emergency exits in school buses, beyond those required by Standard No. 217, Bus Window Retention and Release, must comply with the emergency exit requirements applicable to exits in non-school buses. If the door to which you refer is not designed or constructed as an emergency exit but rather is designed as an additional door for the routine loading and unloading of passengers, it need not be labeled as an emergency exit. If on the other hand the door is intended as an emergency exit and is constructed in accordance with the emergency exit requirements for doors in non-school buses, it should be labeled as an emergency exit in accordance with the labeling requirements for exits in non-school buses.

SINCERELY,

May 21, 1979

Roger Tilton, Office of The Chief Counsel U. S. Department of Transportation

Dear Mr. Tilton:

This letter is a follow-up to our phone conversation of May 18, 1979, relative to the usage of a school bus with a side exit door for mass transit.

We explained that the bus or buses would be used for school transportation and during the off hours would be put into service as transporters for the general public.

The general public use requires a rear side exit door in addition to the entrance door at front side.

Our understanding of the conversation was as follows:

1. Bus would meet all Federal Safety Standards for School Buses.

2. Since the vehicle meets the emergency exit requirements mandated by the Federal Standards for school buses - no emergency exits as noted in FMVSS 217, Sections S5.2 and S5.2.1, are required since the vehicle meets the school bus emergency exit requirements.

3. The side exit door could not be labeled as an emergency exit.

I trust that you concur with my recollection of the conversation, and would appreciate your confirmation of this letter. Thanking you in advance, I remain

James Tydings, Specifications Engineer