Manager, Engineering Services
Blue Bird Body Company
P.O. Box 937
Fort Valley, GA 31030
Dear Mr. Turner:
This responds to your petition for rulemaking dated May 31, 1994. Your petition concerns the following requirement in S184.108.40.206 of Standard No. 217, Bus Emergency Exits and Window Retention and Release:
In the case of windows with one release mechanism, the mechanism shall require two force applications to open.
A similar requirement is included in S220.127.116.11 for emergency roof exits.
Your petition states:
The requirement for two force applications to open a single release mechanism is new and unproven and in our opinion is not in the best interest of safety.
NHTSA agrees that the sentence in question is susceptible to the reading you gave it. So read, this sentence imposes a requirement not intended by the agency. To avoid such unintended readings, the agency should have worded the sentence as follows:
In the case of windows with one release mechanism, the exit shall require two force applications to open.
The agency will issue a corrective notice in the future to make this change. Until the notice is issued, we will not take enforcement action against a manufacturer so long as a window or roof exit with one release mechanism requires two force applications to open the exit.
I hope you find this information helpful. If you have any other questions, please contact Mary Versailles of my staff at this address or by phone at (202) 366-2992.
John Womack Acting Chief Counsel