Interpretation ID: aiam3447
Blue Bird Body Company
Manager
Engineering Services
P. O. Box 937
Fort Valley
GA 31030;
Dear Mr. Turner: This responds to your July 13, 1981, letter asking whether the joint in your school buses that fall within the rear cargo compartment or rear engine compartment must comply with Standard No. 221, *School Bus Body Joint Strength*.; Standard No. 221 applies to joints that connect body panels to bod components. Body panels are defined to include those components that enclose the bus' occupant space. The agency has stated in the past that those portions of a bus falling below the floor level would not be considered as having a function in enclosing occupant space, and accordingly, joints in those area would not be required to comply with the standard's requirements.; Applying the standard to the joints that you question, it appears tha they would not be required to comply with the standard. The agency would consider the walls separating the cargo area or the engine from the remainder of the occupant compartment to be a continuation of the bus floor. Accordingly, joints falling behind and below those walls would not be required to comply with the standard. We do note, however, that the joints along the walls themselves must comply with the standard, since the wall panels enclose the occupant space and provide the separation of the engine or cargo area from the occupant space.; Sincerely, Frank Berndt, Chief Counsel