Interpretation ID: aiam2771
Blue Bird Body Company
P.O. Box 937
Fort Valley
GA 31030;
Dear Mr. Milby: This responds to your January 11, 1978, letter asking whether severa joints in your school bus must comply with 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 (made of homogeneous material) that encloses occupant space in a bus 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 several joints to which you refer, it appears that they do not need to comply with the requirements since they connect panels which are considered to be maintenance access panels.; The National Highway Traffic Safety Administration (NHTSA) notes tha maintenance access panels are granted this exception from the requirements because of their need for removal for routine service to underlying components. The NHTSA will not consider all bus walls as maintenance access panels simply because wiring may be present behind them since routine maintenance would not be required on such wiring. Further, should any of the panels to which you refer in your letter not have wiring or other serviceable components requiring routine maintenance behind them, they will not be treated as maintenance access panels.; Sincerely, Joseph J. Levin, Jr., Chief Counsel