Interpretation ID: nht76-2.11

DATE: 11/24/76

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Sheller-Globe Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This responds to Sheller-Globe Corporation's August 31, 1976, question 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 letter 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 a 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, your acknowledge that the joint where the 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 NHTSA 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 piece-meal 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 eves 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 the 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,

SHELLER-GLOBE CORPORATION Vehicle Planning and Development Center

August 31, 1976

Administrator National Highway Traffic Safety Administration

Reference: Federal Motor Vehicle Safety Standard 221 - School Bus Body Joint Efficiency

Sheller-Globe Corporation respectfully requests interpretation on whether or not certain junctions within the framed structure of the Superior School Bus Body are "joints" by definition, and whether or not these junctions are subject to the requirements of the above referenced Federal Motor Vehicle Safety Standard.

Attached you will find an isometric drawing provided for purposes of your locating the area where these junctions in question are located within the framed structure of the Superior School Bus Body.

Also attached you will find section and part drawings identifiable by section to the isometric drawing provided.

A. Upper Pillar to Windshield Fence - Section 3-3:

The windshield fence is not a body structural member, its only function is to retain the windshield corner glass seal. As can be seen on the isometric drawing provided (Section 3-3), this part is not located within the bus occupant space. It is forward of the drivers seating position in the cab area. This part is fastened to the Number 1 Pillar by are welding.

Sheller-Globe Corporation feels that inasmuch as this part is for functional purposes as referred to in Paragraph S4. Definitions - "Body Panel Joints' and therefore is not subject to the requirements of the above referenced Federal Motor Vehicle Safety Standard.

B. Pillar Facing to Side Body Pillar - Section 5.5, 5.5A and Drawing 62975-B:

This part is not a body structural member, it is as is defined: a "facing", a "trim molding". Its' function is purely decorative as can be seen on Section Drawings 5-5, and 5-5A. This part by virtue of its' construction (rolled or hemmed edges) would provide no sharp, harmful and/or cutting edges in the event of a crash condition. This part is retained to the side body pillar by four (4) rivets, two at the roof rail and two at the sill (see Drawing 62975-B).

Sheller-Globe Corporation feels that inasmuch as this part is for a functional (decorative) purpose as referred to in Paragraph S4. Definitions - "Body Panel Joints" and, therefore, is not subject to the requirements of the above referenced safety standard.

C. Outside Lower Body - Section 9-9: The Superior "Bus Body" sets on the chassis rails (chassis frame) at the lower surface of the underbody main crossmembers (the "O" body line - reference Section Drawing 9-9).

As Paragraph S4. Definitions ("Bus Body") defines the parameters of a bus body, all joints located within these parameters would be required to-comply to the requirements of the above referenced safety standard.

In an interpretation issued by the NHTSA, the fastening of body side rub rails to the outer bus body were excluded from the requirements of the above referenced safety standard. Section Drawing 9-9 (encircled area) depicts where the Skirt Panel is fastened to the Outside Upper Body Panel at the junction where the Body Rub Rail is fastened to the Skirt Panel.

Sheller-Globe Corporation realizes that this junction falls within the defined parameters of a "Bus Body", and accordingly shoull comply with the requirements of the above referenced safety standard. However, Sheller-Globe Corporation requests that this specific junction of the Superior School Bus be exempt from the requirements of the above referenced safety standard for reasons as follows:

A) This junction is located in an area within the structural frame-work of the Superior School Bus Body where probably the highest amount of structural integrity exists, at the bus body floor line perpendicular to the underbody main crossmembers.

B) The steel floor, the Skirt Panel and the underbody main crossmembers are fastened to one another by the 3/8" bolts and nuts, 4 at each body section as can be seen on Section Drawing 9-9.

C) Additionally, the steel floor is joined to the Skirt Panel (upper) in compliance to the requirements of the above referenced safety standard.

D) The Skirt Panel (upper) is joined to the Upper Inside Panel, at the Seat Rail in compliance to the requirements of the above referenced safety standard.

E) All interior and exterior longitudinal panel joints are joined, panel to panel, in compliance to the above referenced safety standard.

F) The steel floor is joined to the underbody main crossmembers in compliance to the requirements of the above referenced safety standard.

Most States require, in their State Specifications, that Rub Rails be installed at the floor-line of School Buses. Denial of this exemption would require that Sheller-Globe Corporation re-engineer this junction configuration, re-engineer and re-tool for the Rub-Rails and Outside Body Panels.

Sheller-Globe Corporation feels that if this junction failed in a crash condition, no loss of body structural integrity would result. Further, feature of this junction in a crash condition would not likely produce edges harmful to the occupants] of the School Bus.

D. Body Rail (Vent Eves) to Outside Roof Panel - Section 12-12A: Section 12-12A depicts where the outside roof panels insert into the roof rail at the vent eves. As further can be seen on Section 15-15, and the isometric drawing provided, the outside roof panels are all fastened as required by the above referenced Federal Motor Vehicle Safety Standard, i.e., 60% Joint Efficiency. The outside roof panels are joined to one another and to the roof bow facings as required by the above referenced Federal Motor Vehicle Safety Standard. Inside roof panels are also joined to one another and to the roof bow facing as required by the above referenced Federal Motor Vehicle Safety Standard.

Presently, where the outside roof panels (as shown on Section 12-12A) inserts into the roof rail (the vent eves), Sheller-Globe Corporation feels that inasmuch as this outside roof panel edge would not, in the event of a crash condition, provide a harmful and/or cutting edge, the junction in reference does not form a part of the body structure, and further inasmuch as all junctions surrounding the junction in reference are joined as required by the above referenced safety standard, the junction in reference would not be required to comply to the requirements of the above referenced safety standard.

If the referenced junction is required to comply to the requirements of the above referenced safety standard, Sheller-Globe Corporation would be required to redesign and retool this area of the bus body structure and its' surrounding structure. The progress of "plug-welding" has been evaluated in joining in this area, however, the results of this process has not been satisfactory in complying with the requirements of the above referenced safety standard. Additionally, "plug-welding" in this area creates an eye-sore and is conducive to rust.

Sheller-Globe Corporation requests interpretation and guidance of the NHTSA pertinent to whether the referenced junction is or is not required to comply with the requirements of the above referenced safety standard.

E. Outside Lower Panel to Inside Lower Panel - Sections 11-11 and 11-11-A:

Sheller-Globe Corporation realizes that where the outside and inside lower panels are joined according to normal interpretation, this joint would be required to comply to the requirements of the above referenced safety standard.

However, Sheller-Globe Corporation requests guidance on whether this joint, inasmuch as it is covered/protected by the trim moulding that is joined to the lower inside panel as required by the requirements of the above referenced safety standard, so that in a crash condition no harmful and/or cutting edges could be produced, need comply to the requirements of this safety standard.

If this joint that is formed by the outside and inside lower panels is required to comply to the requirements of the above referenced Federal Motor Vehicle Safety Standard, Sheller-Globe Corporation would be required to re-design and re-tool this area and its' surrounding structure, possibly to include a re-design and re-tooling of all passenger windows.

Sheller-Globe Corporation solicits the NHTSA's expedient response to this matter, inasmuch as product engineering and tooling engineering for the 1977 model year Superior School Bus is pending an expedient response.

George R. Semark - Manager Vehicle Safety Activities

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APP APP. SYM. REVISIONS DATE CK. DR.: B DATE: 7-27-76 CK. APP. APP. BUS-FRONT END YEAR: 76 (Illegible Words)

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3000 MODEL 1000

SECTION 5-5A

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