Interpretation ID: nht94-4.85

TYPE: INTERPRETATION-NHTSA

DATE: November 18, 1994

FROM: Harry C. Gough, P. E., Automotive Engineering, Professional Specialist, State of Connecticut, Department of Motor Vehicles

TO: Chief Counsel, NHTSA

TITLE: NONE

ATTACHMT: ATTACHED TO 3/16/95 LETTER FROM PHILIP RECHT TO HARRY GOUGH (A43; STD. 217); ALSO ATTACHED TO 7/7/93 AND 3/28/94 LETTERS FROM JOHN WOMACK TO THOMAS D. TURNER

TEXT: Dear Sir:

I am writing on behalf of the State of Connecticut Department of Motor Vehicles. We are requesting a written opinion or interpretation regarding the meaning of the phrase "outlined around it's outside perimeter" as used in FMVSS # 217 S5.5.3, Subsection( c). The term is used in regard to retroreflective tape required to identify emergency exits on school buses. The reason for the request is that a State requirement on the color of school buses requires the rear bumper to be black. One school bus manuf acturer supplied buses with the bottom piece of retroreflective tape required for the rear emergency exit installed on the rear bumper. While discussing options regarding relocation of the bottom piece of tape we were told that installation on the botto m of the door itself (not the opening) was not viable since it would not comply with FMVSS # 217 language. Subsequently a number of new school buses from a different manufacturer which were required to have their emergency exits marked were noted to hav e the tape on the door itself rather than on the edges of the opening.

When the door itself is outlined, the tape is not visible when the door is fully opened. When the edges of the opening for the door are outlined then only the hinge side of the tape is not visible. If only the bottom section of the door outline were on the door itself then both the bottom and hinge side would not be visible when the door is opened.

The ultimate question is; Does the language in FMVSS # 217 allow the required retroreflective tape marking around an emergency exit door to be installed on the door itself?

While I realize your office very busy with such interpretations. I would appreciate a response at your earliest convenience. If there are any additional questions or information required, please feel free to have your office call me at (203) 566-8754.

Thank you in advance for your attention to this matter.