Interpretation ID: aiam2776
Vehicle Planning and Development Center
Sheller-Globe Corporation
3555 St. Johns Road
Lima
OH 45804;
Dear Mr. Premo: This confirms the discussion held among you, Mr. Roger Tilton, Mr. Gu Hunter, and Mr. Martin Paliokas on February 14, 1978, concerning the applicability of Standard No. 221, *School Bus Body Joint Strength*, and Standard No. 113, *Hood Latch Systems*, to your vehicles.; In your first question, you asked whether the joint connecting a piec of metal that is attached to a body pillar and which is covered by the exterior body panels is a joint regulated by Standard No. 221. The standard regulates a 'body panel joint' which is defined as 'the area of contact or close proximity between the edges of a body panel and another body component,....' 'Body panel' is defined as 'a body component...used to enclose the bus' occupant space.' The piece of metal to which you refer becomes a part of the pillar and serves no purpose in enclosing occupant space. Therefore, the joint connecting these two body members is not a body panel joint and is not subject to the standard.; In your second question, you ask whether a hood latch system ca utilize two pin-type latches, one on each side of the hood, to comply with Standard No. 113. The standard specifically permits the use of two hood latch systems. The use of these two distinct pins would appear to comply with the requirements.; Sincerely, Joseph J. Levin, Jr., Chief Counsel