Proposal to define an exemption for handles from “residual/survival space” intrusion requirements for vehicle spaces not intended for occupants. Handles and handholds used to assist passengers in entering and exiting a bus are located outside of passenger seating and standing areas where OICA argues that they do not present a danger; however, the current rollover testing provisions could result in their inclusion in the area defined as “residual/survival space” where any intrusion is prohibited.

Proposal to specify that “handrails and handholds at doorways where the associated residual space is not designated for passengers positioned for travel, and where intrusion into the space presents no risk of contact with passengers, shall also be ignored.”