Interpretation ID: 1983-1.48

TYPE: INTERPRETATION-NHTSA

DATE: 05/02/83

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Truck & Body Equipment Association

TITLE: FMVSS INTERPRETATION

TEXT:

MAY 2 1983 NOA-30

Mr. James E. Forrester Manager of Engineering Services Truck Body & Equipment Association P.O. Box 70409 Washington, D.C. 20088-0409

Dear Mr. Forrester:

This responds to your March 15, 1983, letter asking whether emergency doors in school buses may be marked as "emergency exits" and still comply with Standard No. 217, Bus Window Retention and Release.

Paragraph S5.5.3 states that each school bus exit shall have the designation "Emergency door" or "Emergency exit" as appropriate. The agency has previously determined that emergency doors are considered to be emergency exits and thus can be marked as either doors or exits. Emergency windows must be marked only as emergency exits.

Sincerely,

Frank Berndt Chief Counsel

March 15, 1983

Office of Chief Counsel National Highway Traffic Safety Administration 400 Seventh Street, S.W. Washington, D.C. 20590

Attention: Mr. Roger Tilton

Dear Sir:

One of our members has become involved in a difference of opinion with his customer over the labeling of Emergency Doors and Exits of School Buses, S5.5.3 of FMVSS 217-76.

The issue is that the school bus was manufactured with the emergency doors identified and marked as "doors" and the emergency exits as "exits" in accordance with S5.5.3 of FMVSS 217, now the customer wants the manufacturer to remark the emergency doors as emergency exits. The manufacturer maintains that in so doing he would violate FMVSS-217. Is the manufacturer correct in his interpretation? Your early response will enable a timely resolution to this difficulty.

Your cooperation is greatly appreciated.

Sincerely yours,

James E. Forrester Manager of Engineering Services