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Interpretation ID: aiam2748

Mr. W. G. Milby, Manager, Engineering Services, Blue Bird Body Company, P.O. Box 937, Fort Valley, GA 31030; Mr. W. G. Milby
Manager
Engineering Services
Blue Bird Body Company
P.O. Box 937
Fort Valley
GA 31030;

Dear Mr. Milby: This responds to your January 5, 1978, letter asking whether the join 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 t 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* poin 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, Joseph J. Levin, Jr., Chief Counsel