Interpretation ID: aiam2111
Blue Bird Body Company
P.O. Box 937
Fort Valley
GA 31030;
Dear Mr. Milby: This is in response to your letter of September 23, 1975, in which yo inquire whether the emergency exit decal installations shown in photographs enclosed with your letter comply with paragraphs S5.5.1 and S5.5.2 of Federal Motor Vehicle Safety Standard (FMVSS) No. 217, Bus Window Retention and Release.'; It appears from the photographs you provided that some of the emergenc exit markings may not comply with some of the requirements specified in FMVSS No. 217. Our specific comments are listed below:; 1. Figure 1 - The emergency exit marking for the rear door appears t meet the requirements. It is to be noted, however, that revised requirements for emergency exits on school buses have been proposed which may differ from the current requirements.; 2. Figures 2 and 3 - The emergency exit marking for the side push-ou windows does not appear to meet the requirements of S5.5.2. Both the seat back and the adjacent seated occupant partially obstruct the marking so it is not legible from the adjoining seat or the aisle location.; 3. Figure 4 - The emergency exit marking for the side door appears t meet the requirements.; 4. Figure 5 - The marking for the rear window emergency exit that i adjacent to a davenport type seat with unknown seating capacity appears to contain two release mechanisms (laterally spaced at each edge) and an identical marking for each latch mechanism. We cannot determine if occupants would obstruct these markings from standees if all positions in the davenport type seat were occupied.; We also question whether the instructions are complete because i cannot be determined if both latches must be released before the window can be pushed out.; 5. Figure 6 - The emergency exit marking for the transit sliding typ window appears to meet the requirements.; 6. Figure 7 - The center rear emergency door which contain instructions for unlatching the opening of the door in the form of an arrow only per the proposed amendment to FMVSS No. 217, Docket 75-3: Notice 1 does not meet the present requirements for emergency exit identification. The specific content of the emergency exit marking for school buses has not yet been finalized by this agency and we, therefore, cannot comment until a final rule on the proposal has been published in the *Federal Register*; 7. Figures 8 and 9 - The emergency exit marking for another transi sliding type window appears to meet the requirements.; It is emphasized that these comments are for your information only an are based on the contents of your photographs. This agency cannot make a final judgement concerning compliance of a bus from photographs of components. The determination of compliance or noncompliance with FMVSS No. 217 can be made only by the actual inspection and test of a complete vehicle.; I trust this information will be of assistance to you in regard to you inquiries.; Sincerely, Frank Berndt, Acting Chief Counsel