Why would Keystone remove egress windows from newer models?

[el_jefe1]

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?

[BubDelicious]

Its free to view but you have to create a profile and give up your email address.

National Fire Protection Association

el.jefe wrote:

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.

[el_jefe1]

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.

[BubDelicious]

It appears this part of the specification(NFPA 1192) was updated in the 2015 edition, Vehicles manufactured on or after Sept 01 2014.

[GrandpaKip]

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]

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.

[Fordlover]

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.

[el_jefe1]

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).

[myredracer]

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]

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.

[ktmrfs]

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.

[rbpru]

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.

[Ralph_Cramden]

The egress window requirement is specified by the NHTSA.....not the RVIA. There are records of recalls at NHTSA where RV manufacturers were required to replace standard sliding or
Awning windows with egress type windows. Keystone knows those requirements which they have to meet when they slap the certification label on the side. You need to send your concern to the NHTSA......but Keystone more than likely has already done their homework.

We had a 2013 Keystone Passport Hybrid. On a Hybrid the bunk tents are each an emergency exit as the end window screen is also zippered. Keystone was called out and still had to do a recall and add an emergency type window in the box area due to the dinette and jacknife sofa being able to be used as a sleeping area. The only window that met the size requirement was the window behind the sink so thats where they put the egress window.

So while your ass was in flames you needed to climb over the counter and sink while breaking off the faucet, then you could attempt to squeeze through that small window and drop about 6' while upside down, right on your noggin. It was designed for the Wallendas.

[dodge_guy]

I wouldn't buy a trailer without emergency exit windows in the sleeping areas! on our 07 bunkhouse trailer with its own rear bunk room with an actual door. has 2 egress windows in the bunk room, an egress window in the slideout buy the couch which turns into a bed, and an egress window in our front bedroom.

If they truly put 1 egress window in the whole trailer then they should be held accountable and forced to make the trailer safe! What`s next? taking out LP and smoke detectors because there is a vent fan in the ceiling?

[Ralph_Cramden]

el.jefe wrote:


The RVIA sticker certifies compliance with NFPA 1192. As I understand it, RVIA is a big deal. It would be hard to sell, finance, or insure an rv without it, at least thats what I've been told. I'm not expecting RVIA to do inspections, but it is at least a standard to which manufacturers can be help accountable, isn' tit?

The RVIA is supported financially by the RV manufacturers......solely. What do you think? Scothlock connectors on 12 volt wiring exposed to road spray. Pex fittings crimped to pvc tubing with pex clamps. 120 VAC wiring connected to push in clips on receptacles on something that bounces down the road. Hitch weight subtracted from GVW and tires installed with capacity to that threshold. All it amounts to is a small silver sticker beside the door.

[BB_TX]

myredracer wrote:
Here's what RVIA has to say about NFPA and other standards. Maybe try contacting them? They have no authority to enforce NFPA 1192........

Agree. 1192 is a "standard" meaning it is basically a set of fairly rigid suggestions. A "code" such as the National Electric Code is written in an even more rigid format that governing entities with legal powers can employ as their code for legal compliance to what ever that code applies to.

NFPA has over 100 standards and codes directly or indirectly relating to fire safety.