Interpretation ID: aiam2443
Manager
Vehicle Safety Activities
Sheller-Globe Corporation
Vehicle Planning and Development Center
3555 St. Johns Avenue
Lima
OH 45804;
Dear Mr. Semark: This responds to Sheller-Globe Corporation's August 31, 1976, questio whether 5 described intersections in a bus body qualify as 'body panel joints' subject to the requirements of Standard No. 221, *School Bus Body Joint Strength*.; The windshield fence that you describe in section A of your lette connects the window glazing seal to the bus body and is considered to be a portion of the window by the NHTSA. Windows are excluded from the definition of 'body panel joint' found in S4 of the standard. Therefore, the fence would be excluded from the requirements of the standard.; The 'trim molding' described in section B of your letter constitutes body panel that encloses occupant space. The fact that the trim is decorative does not place it within the exclusion of 'spaces designed for ventilation or other functional purpose.' Since the 'trim molding' is a body panel and is connected to a body component, it creates a joint subject to the requirements of the standard. The fact that the molding, like every other part of the bus, has a function does not exclude it from the ambit of the joint requirement under the exception for 'ventilation or other functional purpose.'; In section C of your letter, you acknowledge that the joint where th skirt panel connects to the outside upper body panel falls within the ambit of the standard. You request an exception from the standard's requirements for this joint based upon a perceived lack of safety hazards resulting from failure of this joint in a crash situation.; To implement the Congressional mandate for school bus safety, the NHTS drafted Standard No. 221 to cover all joints that are potentially dangerous in a crash situation. The agency adopted this broad coverage of joints to avoid the more piecemeal approach of analyzing each joint for possible safety problems, because it is impracticable to test every joint in every possible accident configuration. Therefore, since the joint you describe falls within the parameters of the standard, it must meet the requirements specified.; The joint described in section D of your letter where the vent eve connect to the outside roof panel is a joint within the definition of the standard. The outside roof panel is a 'body panel' as defined in S4. The junction where a 'body panel' connects to a 'body component,' the vent eves, constitutes a joint regulated by the standard.; With regard to section E of your letter, the NHTSA agrees that th joint where the outside and inside lower panels connect is within the scope of the standard. Whether or not the joint itself is covered by trim molding is not relevant to its status. It is still a joint within the definition of the standard and subject to all of the requirements therein.; I trust these interpretations fully answer your questions. Sincerely, Frank A. Berndt, Acting Chief Counsel