Interpretation ID: aiam2528
Paulson and Humphreys
Suite 400
5272 River Road
Washington
DC 20016;
Dear Mr. Burnett: This responds to your February 3, 1977, letter asking whether th intersection of a plywood floor panel and the floor channel structure constitutes a 'body panel joint' 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 the bus' 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 joint you describe, it appears that the joint must comply with the requirements of the standard, because it is the connection of a body component (floor channel structure) with a body panel that encloses occupant space (plywood floor panel).; In your letter, you argue that the standard is not directed at thes types of joints and that in fact the NHTSA stated that not all joints would be regulated by this standard. While it is true that not all joints are regulated by the standard, all joints between the edge of a body panel and a body component are regulated unless expressly excepted from coverage by the language of the standard itself. Since the joint you describe connects a body panel to a body component, it is exactly the type of joint for which coverage was intended.; Finally, you argue that all joints located below the floor are no covered by the standard. This is correct. However, the NHTSA has required floor panels regardless of composition to comply with the requirements of the standard, since these panels form the floor and do not fall below it.; Sincerely, Frank A. Berndt, Acting Chief Counsel