Interpretation ID: 11656-1PJA

Mr. Claude Sauvageau, P.Eng.
74, boul. de la Seigneurie est
Suite 4
Blainville (QuJbec) J7C 4N1

Dear Mr. Sauvageau:

This responds to your letter asking about emergency exit labeling requirements in Federal Motor Vehicle Safety Standard (FMVSS) No. 217, Bus emergency exits and window retention and release. You ask which of two labels your client, an urban bus manufacturer, should use on their emergency exit windows.

As required by S5.3.1 of Standard No. 217, two motions are necessary to open the exits of your client=s buses. The first is to pull down on a red latch at the top center of the window. The second is to push to the left a handle at the bottom right of the window. Your first label depicts only the action of pulling down the red latch. Your second label shows the sequence of first pulling down the red latch and then pushing the handle to the left.

You are correct in your assumption that only the second emergency exit label is permitted. The language in S5.5.1 requires the label to have A. . . the designation >Emergency exit= followed by concise operating instructions describing each motion necessary to unlatch and open the exit . . .@ (emphasis added). The word Aeach@ explains that all necessary motions have to be described. The words Aand open@ explicitly include the motion to open the window. The first label only tells how to unlatch the window, not how to open it. The second label tells how to unlatch and open the window.

I hope this information is helpful. If you have any further questions, feel free to contact Paul Atelsek of my staff at 202-366-5260.

Sincerely,

Samuel J. Dubbin Chief Counsel ref:217 d:4/29/96