Interpretation ID: aiam2530
Manager
Engineering Services
Blue Bird Body Company
P.O. Box 937
Fort Valley
GA 31030;
Dear Mr. Milby: This responds to your February 9, 1977, letter asking whether 1 described intersections of bus body components qualify as 'body panel joints' subject to the requirements of Standard No. 221, *School Bus Body Joint Strength*.; The terms which establish the applicability of the requirements of th standard to a particular section of a school bus body are defined in S4 of the standard. Read together, they establish the following test. If the edge of a surface component (body panel) that encloses occupant space comes into contact or close proximity with any other body component, the requirements of S5 apply, unless the area in question is designed for ventilation or another functional purpose or is a door, window or maintenance access panel. Applying this test to the 10 intersections of bus body components you describe, it appears that none of them are required to comply with the standard.; The joints numbered 1 through 4 on page 1 of your letter refer t hanger straps, panels and pads involved in the installation of overhead storage racks. These items of equipment are not considered to have a function in enclosing occupant compartment space and, therefore, are excluded from the standard's requirements.; The exterior roof luggage rack described in paragraphs 5 and 6 is no considered to have a function in enclosing occupant space and, therefore, is not considered a body component for purposes of the requirements. For purposes of testing the complex joints to which the rack is fastened, it should be modified as necessary to prevent it from affecting testing of the underlying joint.; The NHTSA agrees that the joints described in paragraphs 1 through 4 o page 2 of your letter, relating to the installation of air conditioning units, involve the type of ventilation space that is not subject to the requirements for joint strength.; Sincerely, Frank Berndt, Acting Chief Counsel