Short version: It seems to be (through a very brief and unscientific facebook poll on the Passport owners page) that older model bunkhouse trailers always had fire escape windows, but now the same newer Passport models do not. And it's got me wondering, what is the advantage to the manufacturer of putting in regular slider windows instead of egress escape windows?Longer version: I've been discussing this at length over in the Keystone forums, and with Keystone directly. My 3290bh has no escape windows in the bunkhouse. I didn't notice it until I'd had the trailer a couple of weeks. Yes, I should have caught it before I bought it, I know.But actually there is only one escape window in the whole trailer, and it's in the front bedroom. Other than that, it's only a door to get out, no other emergency exits. The bunkhouse is designed to sleep 6, and it has 2 windows, both are the small slider type that only open halfway. Neither is large enough for even a small child to fit through. My argument to Keystone has been (and still is unresolved) that they advertise compliance with RVIA standards and claim the trailer meets NFPA 1192. But if a sleeping area only has one path to escape, then it does not meet that standard. In my view, if it can be proved that the trailer doesn't meet that standard, regardless of how it is designed, they should modify it to meet the standard. But it's still got me wondering - they used to have egress windows back there. I've seen 2015 and 2016 models with them. Why remove them from 2018 and 2019 models? What is to be gained by Keystone? Especially if they've removed them to the point that they are no longer actually in compliance with the NFPA standard?

Don’t know about Keystone but in my MH the egress window is small and not meant to be opened except for emergency exits. NO screen, NO way to prop it open. Some owners have modified it to be useable as a ventilation window. As is, it is doubtful that the window is helpful in the case of a fire. Perhaps Keystone is in compliance and the beef might be better aimed at the standard. I have no clue as to why they would swap out an egress windows for a slider one, UNLESS the egress widow is not usable for ventilation as is the case in my MH.

I don't think that's it, as the egress window in the front bedroom has a screen and works for ventilation just fine. From what I'm reading in NFPA (which is part of the RVIA) sticker on the side, each sleeping area must have 2 exits. The door is one, but there must be another one. As I'm reading it, my trailer is actually out of compliance with the NFPA standard, even though they claim it meets it.That's why I don't understand it. Is an emergency window of a similar size that much more expensive than a slider?

NFPA is not part of RVIA. Separate entities. However, RVIA uses the NFPA 1192 standard as their standard for design of RVs. Much like cities use NFPA 70 National Electric Code for their building codes.The NFPA 1192 standard is a little grey in that area. It states that where an RV has more than one sleeping area and one area uses the door as the primary means of escape then no other means of escape is required for that area. That is a pretty far reach for the manufacturer to claim the forward door is the primary means for escape from a rear sleeping area, but I would guess that is their poor reasoning.For a MH, 1192 permits the driver's door can be the secondary exit. That means a long MH with sleeping in the rear would be permitted to use the two doors at the front as the primary and secondary means of escape.Would probably require a law suit and a court legal ruling to get any action from the manufacturer. But it would not hurt to push it as far as you can without getting into court battles.

Here's what RVIA has to say about NFPA and other standards. Maybe try contacting them? They have no authority to enforce NFPA 1192. What they say is "The primary goal of the Standards Department Inspection Program is to monitor the pledge of member manufacturer’s to build in conformance to these adopted standards.". In order for a manufacturer to get the RVIA seal, the manufacturer "certifies" compliance with 1192. "Certify" or "pledge" is more like a "cross my heart, hope to die" promise that doesn't mean much. I've found a lot of things that don't comply with the NEC that would never happen or be allowed in building construction. I have to think RVIA's "Inspection Program" is a smoke and mirrors program.

NFPA 11926.2.1.2 Each bedroom or area designed for sleeping shall have at least two unobstructed paths to exit.(Keystone is saying that since it is a curtain separating the bunkhouse from the rest of the trailer and not a door it doesn't count as a separate room. Either way, the egress window is behind a door in the front bedroom)6.2.1.3 The path to exit shall not require passing any designated exit to gain use of another designated exit except where any part of a bed in its normal sleeping configuration is within 24 in. (610 mm) of the plane of the nearest designated exit as projected across the vehicle.(I don't fully understand what they are saying at the end, but the egress window is forward of the exit door, so it wouldn't seem to be a valid path to escape from the rear bunkhouse)6.2.5.1 The alternate exit, if not an exterior passage door, shall provide an opening ofsufficient size to permit unobstructed passage, keeping the major axis parallel to the plane ofthe opening and horizontal at all times, of an ellipsoid generated by rotating about the minoraxis an ellipse having a major axis of 24 in. (610 mm) and a minor axis of 17 in. (432 mm).(My slider windows might fit this standard if they opened all the way, but they don't open far enough.)By all of these sections, I believe the 2018 3290bh fails to meet the NFPA standard.

Why would Keystone remove egress windows from newer models?

rbpru
Explorer II
Aug 21, 2018
On the surface it would seem to be an oversight and worth a call to the TT manufacturer. Perhaps even a call to the oversight agency.

However, as already mentioned, it is most likely a matter of interpretation of the rules, as opposed to an oversight.

Certainly a question worth asking.
ktmrfs
Explorer II
Aug 21, 2018
all this is interesting discussion. Our outback 295 has one sleeping area designated, the bedroom, which has an egress window which also serves for ventilation. In the main living area there is the usual fold out couch/bed and behind the couch is yet ANOTHER Egress window. It's the push out no venting type.
el_jefe1
Explorer
Aug 22, 2018
Keystone's answer today:
"Thank you for contacting Keystone RV. I did review with my manager, and my manager reviewed with the general manager, we are not going to be participating on any modification to our units, you can most definitely install an extra escape window but it would be at your cost, it can also affect your warranty in the future. However, Keystone RV will not participate in any modifications."

I'll be following up with RVIA and NHTSA next, I guess. The question of whether the RV meets the standard still has not been answered. First they tried to answer the question by pointing out the lack of a door on the bunkhouse means they believed they were still in compliance. But when I pointed out the door to the bedroom is still between the bunkhouse and the fire escape, they dropped the question of compliance altogether and just said "No." It seems like Keystone is trying to sidestep the whole question.
myredracer
Explorer II
Aug 22, 2018
What about trying Trailer Life magazine?

Ralph Cramden wrote:
The egress window requirement is specified by the NHTSA.....not the RVIA.
Curious if you might have a link to their requirements?
el_jefe1
Explorer
Aug 22, 2018
myredracer wrote:
Curious if you might have a link to their requirements?

The RVIA sticker on the side of our trailers says "Manufacturer certifies compliance with standard for recreational vehicles NFPA 1192"

Specifically it fails in at least two areas:
6.2.1.2 Each sleeping area shall have two different paths to escape to the outside of the recreational vehicle.

6.2.5.1 Means of escape, if not an exterior passage door, shall provide an opening of sufficient size to permit the unobstructed passage, with its major axis parallel to the plane of the opening and horizontal at all time, of an ellipsoid generated by rotating about the minor axis an ellipse having a major axis of 24 in. (610 mm) and a minor axis of 17 in. (432 mm).
Fordlover
Explorer
Aug 23, 2018
Hope you keep us updated with what the NHTSA comes back with. I'm going to take a look at the windows in our bunks, I seriously doubt they are egress windows.
BubDelicious
Explorer
Aug 23, 2018
First thing to do when reading any specification is to make sure you are reading the right one.
NFPA 1192, 2018 Edition, vehicles manufactured after Sept 01 2017.

6.2.1.2.1 Where more then one sleeping area is provided and a sleeping area has a door as a primary means of escape to the outside of the recreational vehicle, no additional escape shall be required for this area.

The way I see it, if your bunk house does not have a door to close it off from the rest of the trailer then the primary escape is the outside door and no additional escape is required. Iam assuming your front bedroom has a door to close it off from the rest of the trailer, which requires an addition escape (window).

el.jefe wrote:
NFPA 1192

6.2.1.2 Each bedroom or area designed for sleeping shall have at least two unobstructed
paths to exit.

(Keystone is saying that since it is a curtain separating the bunkhouse from the rest of the trailer and not a door it doesn't count as a separate room. Either way, the egress window is behind a door in the front bedroom)

6.2.1.3 The path to exit shall not require passing any designated exit to gain use of another
designated exit except where any part of a bed in its normal sleeping configuration is within
24 in. (610 mm) of the plane of the nearest designated exit as projected across the vehicle.

(I don't fully understand what they are saying at the end, but the egress window is forward of the exit door, so it wouldn't seem to be a valid path to escape from the rear bunkhouse)

6.2.5.1 The alternate exit, if not an exterior passage door, shall provide an opening of
sufficient size to permit unobstructed passage, keeping the major axis parallel to the plane of
the opening and horizontal at all times, of an ellipsoid generated by rotating about the minor
axis an ellipse having a major axis of 24 in. (610 mm) and a minor axis of 17 in. (432 mm).

(My slider windows might fit this standard if they opened all the way, but they don't open far enough.)

By all of these sections, I believe the 2018 3290bh fails to meet the NFPA standard.
GrandpaKip
Explorer II
Aug 23, 2018
Interesting that in ours, there is an egress window by the bed and another behind the dinette. The only door inside is to the head. The two windows are about 6’ apart.
When our kids had their EcoCamp bunkhouse, it had three of them in a 21’ box.
BubDelicious
Explorer
Aug 23, 2018
It appears this part of the specification(NFPA 1192) was updated in the 2015 edition, Vehicles manufactured on or after Sept 01 2014.
el_jefe1
Explorer
Aug 23, 2018
BubDelicious wrote:

6.2.1.2.1 Where more then one sleeping area is provided and a sleeping area has a door as a primary means of escape to the outside of the recreational vehicle, no additional escape shall be required for this area.

Ha, well where were you a week ago? Lol.
Do you have a link to the updated version? There are still a couple things I wonder about, though it appears from what you've posted the manufacturer has more than enough wiggle room to obey the letter of the standard without adhering to the spirit of it.

What I read earlier had a not about beds in their normal sleeping position, and having to have a wide enough path. 13 inches, I believe it was. Would that apply to sofa sleepers?

I also think it's interesting that they designate "sleeping areas" rather than "rooms". By Keystone's interpretation, you could have a 40' long trailer with only a door at the far end as long as you don't put and interior doors in it.