ARM REST FAILURES

SUMMARY: IN THE MCI RESPONSE TO NHTSA INQUIRY, THE AGENCY LEARNED THAT THESEATS INSTALLED IN THE MCI COACHES WERE MANUFACTURED BY WAKEFIELD. MUCH OFTHE INFORMATION REQUESTED BY NHTSA FROM MCI IS IN THE POSSESSION OFWAKEFIELD. A PE HAS BEEN OPENED AND A INFORMATION REQUEST SENT TOWAKEFIELD TO OBTAIN THIS ADDITIONAL INFORMATION. INFORMATION SUPPLIED BYNTSB HAS SUGGESTED THAT ADDITIONAL BUS MANUFACTURERS MAY ALSO BE INVOLVED,AS WELL AS A MANUFACTURER OF SEAT FRAMES WHICH ARE USED BY WAKEFIELD.BASED ON THE NTSB INVESTIGATION AND THE REPORTS WHICH THEY FURNISHED TONHTSA, THIS PROBLEM MAY HAVE SERIOUS SAFETY IMPLICATIONS. AS MCI IS THEMANUFACTURER OF THE COMPLETED VEHICLE, MCI WOULD HAVE PRIMARYRESPONSIBILITY SHOULD RECALL ACTION BE REQUIRED.===ODI ANALYSIS: CLOSE EXAMINATION OF PHOTOS TAKEN OF THE BUS WHICH WASINVOLVED IN THE SINGLE REPORTED INCIDENT, AND AN ACTUAL EXAMINATION OF AMCI BUS OF THE SAME MODEL AS THE MODEL INVOLVED, INDICATE THAT THE SEAT ARM RESTS WOULD MAKE ALMOST PERFECT SETS OF STAIRS FOR ANYONE TRYING TO EXITFROM THE BUS THROUGH EITHER EMERGENCY EXITS OR THE BUS WINDOWS, IF THE BUSWERE RESTING ON ITS SIDE. AS THIS IS THE ONLY REPORT RECEIVED IN THE 9YEARS THAT THE SEAT HAS BEEN IN PRODUCTION, THE WAKEFIELD ANALYSIS SEEMSREASONABLE (EG) ESCAPING PASSENGERS USED THE ARM RESTS AS A STAIRCASE TOESCAPE THE OVERTURNED BUS, AND THE ARMREST FRACTURES WERE RESULTANT FROMTHAT USE.