Ms. Jane L. Dawson
Thomas Built Buses, Inc.
P.O. Box 2450
1408 Courtesy Road
High Point, NC 27261
Dear Ms. Dawson:
This responds to your April 1, 1996, letter seeking clarification about some conclusions contained in an interpretation dated March 20, 1996 from this office to Mr. Tom Turner of the Blue Bird Body Company, concerning Federal Motor Vehicle Safety Standard No. 217, Bus emergency exits and window retention and release. You have correctly identified statements in the March 20, 1996, letter to Mr. Turner that should be corrected.
In the March 20 letter, we state that voluntarily installed left side emergency exit doors do not have to meet the location requirements of S188.8.131.52. You agree with that position. However, the March 20 letter then states:
voluntarily installed side exit doors would still be subject to prohibitions and requirements that apply to side exit doors generally. For example, S184.108.40.206(a)(4) prohibits installing two side exit doors "in whole or in part, within the same post and roof bow panel space." In addition, section S220.127.116.11(a)(1) requires "each" side exit door to be hinged on its forward side (not merely those doors installed pursuant to Table 1).
As you point out, the scope of all the requirements of S18.104.22.168 is limited by the introductory sentence of S22.214.171.124, which states "[a]ll emergency exits required by S126.96.36.199(a) and S188.8.131.52(b) shall meet the following criteria: . . ." (emphasis added).
You are correct that the scope of S184.108.40.206's requirements is limited by S220.127.116.11's introductory sentence, and that none of the requirements of that section apply to voluntarily installed exits. To the extent that the March 20 letter stated otherwise, it was incorrect. It would be preferable if voluntary exits conform to S18.104.22.168, so that there will be no differences in hinging, spacing and location that may confuse occupants in an emergency.
This letter also clarifies another point made in the March 20, 1996 letter to Mr. Turner. We state in the third paragraph that voluntarily installed exits on school buses "should" meet the requirements of Standard No. 217, to avoid confusing occupants who may choose the exit for emergency egress. The discussion may have implied that voluntarily installed exits are excluded from Standard No. 217's requirements, which would be incorrect.
Standard No. 217 establishes requirements "for bus emergency exits." (See section S1 of the standard.) Most of the standard's requirements apply generally to all school bus emergency exits, without regard to whether an exit is required or voluntarily installed. All the requirements that apply to exits generally, i.e., which use terms such as "each" or "any" when describing the exit to which the requirement applies, apply to voluntarily installed exits. In some instances, the standard's requirements only apply to a required school bus emergency exit (e.g., S5.5.3(a) and (c), emergency exit identification). Requirements that apply only to required exits do not apply to voluntarily installed exits.
Thank you for bringing the error to our attention. If you have further questions or concerns, please call Paul Atelsek of my staff at (202) 366-2992.
Samuel J. Dubbin
cc: Mr. Thomas D. Turner
Blue Bird Body Company
NCC-20:PAtelsek:6-2992:5/1/96: revised 7/22/96
cc: NCC-01 Subject/chron
Interp. Std. 217, Redbook (2)