Interpretation ID: nht90-3.60

TYPE: Interpretation-NHTSA

DATE: August 16, 1990

FROM: Thomas D. Turner -- Manager, Engineering Services, Blue Bird Body Company

TO: Paul Jackson Rice -- Chief Counsel, NHTSA

TITLE: Re Reference: 49 CFR, Part 571.221 School Bus Body Joint Strength

ATTACHMT: Attached to letter dated 1-14-91 from Paul J. Rice to Thomas D. Turner (A37; Std. 221); Also attached to undated letter from Frank Berndt to W.G. Milby; Also attached to letter dated 3-18-77 from Frank Berndt to W.G. Milby

TEXT:

Section S4 of the referenced standard provides the following definition:

"Body panel joint" means the area of contact or close proximity between the edges of a body panel and another body component, excluding spaces designed for ventilation or another functional purpose, and excluding doors, windows, and maintenance access pa nels.

In an April 26, 1976 letter to Blue Bird (reference N40-30) NHTSA stated: "Your assumption that components located entirely below the level of the floor line are not subject to the standard is correct."

The enclosed drawing 1519834 illustrates the joints of a Blue Bird stepwell to the Number 1 and 2 floor sections. Since the stepwell is a space designed for a functional purpose, it is our understanding that it is excluded from the requirements of the s tandard. The fact that the actual joint and all components of the stepwell are located entirely below the level of the floor line also constitutes the basis for exemption from the standard.

Based on these facts, it is Blue Bird's interpretation that the joints of the stepwell to the floor sections, as shown in drawing 1519834 are not subject to the joint strength requirements of FMVSS 221. We request your early consideration of this matter and confirmation that our interpretation is correct.

Attachment

Correspondence Log Wednesday 09/19/90 11:41 am For: BURRILL, Peggy Entry Number: 5110 Date Received: 08/21/90

Correspondence Date: 08/16/90 Entry Type: LTR Received from Company: Blue Bird Person: Thomas D. TurnerRE: Req. interpretation of FMVSS 221 as it pertains to the stepwell. See attached drawing 1519834 Routed to: NCC-20 *** 8/21/90 Follow up date: 10/09/90 Response date: / / Referred to: DG Filed: