Interpretation ID: nht94-7.6

DATE: April 4, 1994

FROM: William G. Franz -- Vice President, Fabrication, Wells Aluminum

TO: Walter Myers -- NHTSA

TITLE: Federal Motor Vehicle Safety Standard No. 217

ATTACHMT: Attached to letter dated 8/5/94 from John Womack to William G. Franz (Std. 217)

TEXT: Dear Mr. Myers:

Subsequent to our recent phone conversation, I am formally requesting an interpretation of paragraph S.5.1.2 regarding the window opening size. Specifically, my question is as follows:

Does the 8 inch window opening size apply to the total outside frame dimension or does it apply to each pane of glass? The enclosed picture shows a typical retention test being performed on a push out window with two separately framed pieces of glass. In other words, would a pane of glass which measures less than 8 inches across need to be subject to the retention test?

For your information, Wells Aluminum Corporation manufactures push out windows for the school bus industry.

I look forward to your response.

WGF/cih

myers.ltr