Interpretation ID: aiam2734
Manager
Engineering Services
Blue Bird Body Company
P. O. Box 937
Fort Valley
GA 31030;
Dear Mr. Milby: This responds to your October 24, 1977, letter asking whether th framework of a roof hatch must comply with the requirements of 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 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 frame of a roof hatch, it appears that this joint need not comply with the requirements. This conclusion is reached because the National Highway Traffic Safety Administration concludes that a roof hatch is equivalent to a door or window for the purposes of the application of the requirements. The joint connecting the frame of a door, window, or roof hatch to a bus body falls within the exception to the applicability of Standard No. 221.; Sincerely, Joseph J. Levin, Jr., Chief Counsel