Interpretation ID: nht90-1.54

TYPE: Interpretation-NHTSA

DATE: February 22, 1990

FROM: Keith D. Kroll -- Vice President, Engineering., Hehr International. Inc.

TO: Stephen P. Wood -- Acting Chief Counsel., NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 5-13-90 To Keith D. Kroll and From Stephen P. Wood; (A35; Std.217); Also attached to letter dated 1-26-90 To John G. Sims and From Stephen P. Wood

TEXT:

Hehr International, Inc. manufactures windows and emergency exit windows for buses. We are looking for clarification of the marking of and operating instructions for window emergency exits; specifically, the requirements of paragraphs S5.5.1 and S5.5.2 o f Federal Motor Vehicle Safety Standard (FMVSS) 217, Bus Window Retention and Release.

Per paragraph S5.5.1 of FMVSS 217, "...and each push-out window or other emergency exit shall have the designation "Emergency Exit" followed by concise operating instructions describing each motion necessary to unlatch and open the exit, located within 6 inches of the release mechanism." We interpret this as two labels; one designating the "Emergency Exit" and the other giving unlatching instructions located 6 inches from the latch/es.

With this interpretation, it follows that the legibility requirements of paragraph S5.5.2 apply only to the "Emergency Exit" marking and not to the unlatching instructions. Additionally, S5.5.2 requires the marking must be legible from the aisle with the seats occupied. Again, we interpret this to apply to the "Emergency Exit" marking only. There are many seating configurations where the latch and unlatching instructions (6 " from the latch) are not visible from the aisle because the "adjacent seat" passenger totally covers them.

Our position has, on numerous occasions, been discussed with NHTSA engineers. The most recent was 23 October 1989 with Jeff Jiusippe who further reviewed this with his supervisor, Mr. Robert Kraus, and called back the same day stating that they (NHTSA) a greed with our position.

We receive numerous calls from our various bus window customers on the legibility of the 'unlatching instructions' to which we respond with our position that the 'unlatching instructions' do not have to meet the legibility requirements of paragraph S5.5. 2; S5.5.2 applies to the exit identification only.

We request your written concurrance with the preceeding interpretation of FMVSS paragraphs S5.5.1 and S5.5.2.