Interpretation ID: aiam2869
Chief Design Engineer
Ward Industries
Inc.
P. O. Box 849
Conway
AR 72032;
Dear Mr. Ryan: This responds to your August 22, 1978, letter asking whether you proposed emergency door label complies with the requirements of Standard No. 217, *Bus Window Retention and Release*.; Paragraph S5.5.3 requires that each school bus emergency exit shal have the designation 'Emergency Exit' or 'Emergency Door' as appropriate, in letters at least 2 inches high, of a color that contrasts with its background, located at the top of or directly above the emergency exit on both the inside and outside surfaces of the bus. The label that you propose would be located on the inside of the glass but would be visible from the outside of the vehicle.; The National Highway Traffic Safety Administration (NHTSA) ha indicated in the past that the location of the emergency exit label can be directly above or on the top half of the emergency exit. Your location near the top of the glass on the rear emergency door appears to fall within this acceptable area. The standard further requires that the label be located on both the inside and outside surfaces of the bus. The intent of this requirement is to provide a visible emergency exit designation on both the inside and outside of a bus. Since your label would be visible outside the school bus even though its location would be on the inside of the glass, the NHTSA concludes that it complies with this requirement. In reaching this conclusion, the agency assumes that you will have a similar label that will be visible inside the bus.; In summary, since your described label is the required size, consist of contrasting colors, and is placed in the appropriate location, it appears to comply with the requirements of Standard No. 217.; Sincerely, Joseph J. Levin, Jr., Chief Counsel