Interpretation ID: nht90-1.30
TYPE: Interpretation-NHTSA
DATE: January 29, 1990
FROM: Cal Karl -- District 4700 - Commercial Vehicle Section, State of Minnesota, State Patrol Division
TO: Marvin Shaw -- Chief Counsel, NHTSA
TITLE: None
ATTACHMT: Attached to letter dated 1-18-90 from R. E. Meadows; Also attached to letter dated 1-8-90 from R. Marion to C. Karl; Also attached to memo dated 11-28-8? from C. Karl to All School Bus LCR II's; Also attached to letter dated 11-27-90 from P.J. Rice to C. Karl (A36; Std. 217); Also attached to letter dated 12-7-82 from F. Berndt to M.B. Mathieson
TEXT:
I am in charge of the school bus inspection program for the Minnesota State Patrol. In that capacity I am asking for your interpretation of 49 CFR 571.217 S5.2.3.2 regarding vandal locks.
I have become aware of vandal locks by some bus body manufacturers that I feel do not meet the requirements of 217. My interpretation is disputed by the manufacturers and therefore I ask for your interpretation.
We are finding many of the vandal locks that even though they are unlocked, and the bus can start and run, the lock may be relocked by a student while the bus is running. Granted, it would not kill the bus engine but would render the starting mechanism inoperable if the engine is shut off or would die. This situation appears loaded with potential danger if the driver finds himself in a precarious situation and kills the engine only to find it won't restart.
Some manufacturers combat that by incorporating an interlock that activates a buzzer in the driver compartment if the lock is locked. This warns the driver that lock has been locked but doesn't prevent him from getting into a predicament before he is ab le to cause the door to be unlocked.
While standard 217 prohibits a bus from starting if the vandal lock is locked, can the lock be relocked after the bus is running or should it be locked in the open position?
While standard 217 requires that a key or special information by the driver is required to unlock the device, may it then be relocked without the key or special information?
I have enclosed copies of Minnesota minimum standards and letters from Wayne Bus Co. and Thomas Built Bus Co.
I appreciate your consideration.
Attachment
Minnesota Minimum Standards for School Bus 3520.5010 Doors
The emergency door must be equipped with a slide-bar cam-operated lock. The slide bar must have a minimum stroke of one inch. The emergency door lock must be equipped with a suitable electric plunger type switch connected with a buzzer located in the dr iver's compartment. The switch must be enclosed in a metal case, and the wires leading from the switch must be concealed in the bus body. The switch must be installed so that the plunger contacts the farthest edge of the slide bar so that any movement of the slide bar immediately closes the circuit on the switch and sets off the buzzer.
The emergency door lock must be equipped with an interior handle that extends approximately to the center of the emergency door. The handle shall lift up to release the lock.
The service door and the emergency door (side or rear) may be equipped with vandal locks if the locks comply with Federal Motor Vehicle Safety Standard Number 217, Code of Federal Regulations, title 49, part 571.
MS s 169.45
13 SR 1860
3520.5020 (Repealed, 13 SR 1860)
3520.5100 (Repealed, 13 SR 1860)
3520.5110 (Repealed, 13 SR 1860)
3520.5111 FIRE EXTINGUISHER.
A minimum of one 2-1/2 pound dry chemical type fire extinguisher, with not less than a 10-B-C rating, is required. It must be approved by underwriters Laboratories, Inc. or an equivalent testing laboratory.
The extinguisher must be mounted in a bracket, located in the driver's compartment and readily accessible to the driver and passengers. A pressure indicator is required and must be easily read without removing the extinguisher from its mounted position.
MS s 169.45
13 SR 1860
3520.5120 FIRST AID KIT.
The bus must carry a removable Grade A metal, or other material of equal strength, dust-proof first aid kit, mounted in full view or in a labeled accessible place in the driver's compartment.
The first aid kit must have the following units and packages per unit: