Interpretation ID: nht87-2.80

TYPE: INTERPRETATION-NHTSA

DATE: 08/28/87

FROM: S. T. MESSINA, -- NJ DEPT OF TRANSPORTATION

TO: TERRY K. BROCK -- COONS MANUFACTURING INC.

TITLE: COONS MANUFACTURING INC. DIAMOND VIP BUS 25 PASSENGER MC 157-87

ATTACHMT: ATTACHED TO LETTER DATED 06/30/88 FROM ERIKA Z JONES TO TERRY K BROCK; RED BOOK A32, STANDARD 217; LETTER DATED 09/09/87 FROM TERRY K. BROCK TO STEVE KRATZKE RE CLARIFICATION OF FMVSS CODE 217, OCC-1009; LETTER DATED 08/20/87 FROM TERRY K. BROC K TO SEBASTIAN MESSINA

TEXT: Dear Mr. Brock,

This is in reply to your letter of August 20, 1987 pertaining to emergency escape areas.

Parts 393.61, 393.62 and 393.63 of the Federal Motor Carrier Safety Regulations require that emergency exits comply with Federal Motor Vehicle Safety Standard 217. The escape areas are to be through windows of a push out type. The ordinary opening o f a window for ventilation should not be included due to possible jamming.

The front entrance door cannot be considered since the intent of the regulations is to provide emergency escape through push out windows and roof escape hatches.

I hope that we have been of assistance.