Interpretation ID: nht78-1.32

DATE: 02/14/78

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

TO: Blue Bird Body Company

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your January 5, 1978, letter asking whether the joint connecting the front roof cap to the windshield header is considered a joint subject to the requirements of Standard No. 221, School Bus Body Joint Strength.

Standard No. 221 applies only to joints connecting body components to body panels in a bus body. Bus body is defined as "the portion of a bus that encloses the bus's occupant space, exclusive of the bumpers, the chassis frame, and any structure forward of the forwardmost point of the windshield mounting." Any joint falling outside the area prescribed for the definition of bus body is not considered a joint subject to the standard.

If the joint to which you refer is forward of the forwardmost point of the windshield mounting, it is not subject to the requirements of the standard. The location of this joint, however, is not clear from your letter. The second paragraph of your letter indicates that the lower portion of the windshield glass extends forward of the referenced joint. If the lower portion of the windshield mounting as well as the glass is forward of the joint in question then that joint lies within the area defined as the "bus body" and is subject to the requirements of the standard.

SINCERELY,

BLUE BIRD BODY COMPANY

January 5, 1978

Joseph J. Levin, Jr. Chief Counsel National Highway Traffic Safety Administration

Dear Mr. Levin:

SUBJECT: 571.221 Standard No. 221, School Bus Body Joint Strength

Section S4 defines a bus body as follows: "Bus body" means the portion of a bus that encloses the bus's occupant space, exclusive of the bumpers, the chassis frame and any structure forward of the forwardmost point of the windshield mounting.

Blue Bird school buses have a joint between the front roof cap and windshield header which is forward of the upper portion of the windshield glass, rubber and metal flange mounting. This joint "A" is illustrated in the enclosed photograph. The lower portion of the windshield glass protrudes forward of the subject joint. Based on paragraph S4, it is our understanding that joint "A" between the front roof cap and windshield header is exempt from the requirements of S5 because it is forward of the forwardmost point of the windshield mounting.

Would you please give us a ruling on this at your earliest convenience.

W. G. Milby Manager, Engineering Services

Windshield Glass

Windshield Mounting Rubber

(Graphics omitted)