Interpretation ID: nht89-1.21

TYPE: INTERPRETATION-NHTSA

DATE: 02/14/89

FROM: KAREN E. FINKEL -- EXECUTIVE DIRECTOR NATIONAL SCHOOL TRANSPORTATION ASSOCIATION

TO: JOAN TILGHMAN -- NCC-20 NATIONAL HIGHWAY TRAFFIC SAFETY ADMIN. U.S. DEPT. OF TRANSPORTATION

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 04/27/89 FROM ERIKA Z. JONES -- NHTSA TO KAREN E. FINKEL, REDBOOK A33(2), STANDARD 217

TEXT: Dear Joan:

As we discussed on the phone earlier this week, NSTA members (who are school bus contractors) have a question regarding push-out windows on school buses.

The Federal Motor Carrier Safety Standards, Sec. 393.61, states that push-out windows are required and that they must conform to Federal Motor Vehicle Safety Standard No. 217. However, in reading FMVSS 217, there are different requirements for buses and school buses. School buses are not required to have push-out windows. Therefore, the question arises whether school buses being used by school bus contractors in interstate commerce, for other than to and from school work, must have push-out windows.

Because many contractors are purchasing buses now in order to have delivery for the coming school year, and they do not know whether to purchase them with push-out windows or not, I would appreciate a very response to this question.

Thank you for your assistance in clearing up this confusion. If you have any questions, please let me know.

Sincerely,