Interpretation ID: 77-5.16

TYPE: INTERPRETATION-NHTSA

DATE: 12/26/77

FROM: AUTHOR UNAVAILABLE; J. J. Levin, Jr.; NHTSA

TO: Wayne Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your oral request to Roger Tilton of my staff for the reasons that the National Highway Traffic Safety Administration (NHTSA) exempted buses with gross vehicle weight ratings of 10,000 pounds or less from the requirements of Standard No. 221, School Bus Body Joint Strength.

As you know, the NHTSA promulgated the joint strength standard to prevent injuries resulting from the impact of children with the sharp protruding edges of body panel sheets that become unfastened in school bus accidents. This problem, according to the information available to the agency, was particularly acute with respect to large school buses. The agency has no similar data indicating that the joint severance problem is a major factor contributing to injuries in accidents involving smaller school buses. Accordingly, the agency exempted those vehicles from the requirements. Should the NHTSA discover in the future that such problems exist with respect to smaller buses, it would consider extending the requirements to them.

I am enclosing a copy of our last notice on Standard No. 221 that fully outlines our reasons for exempting smaller school buses.