Interpretation ID: aiam3437
School Bus Manufacturers Institute
Truck Body and Equipment Association
5530 Wisconsin Avenue
N.W.
Suite 1220
Washington
DC 20015;
Dear Mr. Sweet: This responds to your January 19, 1981, letter making several comment about the agency's plan to modify Standard No. 221, *School Bus Body Joint Strength*, as it applies to maintenance access panels in school buses. I want to apologize for the delay in responding to your letter which was inadvertently combined with another agency action.; First, you disagree with an agency statement that manufacturers hav taken advantage of the existing maintenance access panel exemption from the standard's requirements. The agency's concern arises from several types of practices. Several manufacturers have produced buses with panels that have no wiring or other mechanisms behind them requiring maintenance. Other manufacturers have declared almost the entire rear walls of their buses as access panels. We believe that this is beyond the scope of the exemption of maintenance access panels from the standard's requirements.; Second, you ask several questions about supporting data for th standard and our planned modification of the standard. The agency is gathering information at this time and will make that data public when and if a rulemaking notice is issued.; Finally, you refer to unspecified agency statements relating t enforcement issues of noncomplying buses. We are unable to respond to this series of questions, because we are not immediately familiar with the correspondence to which you refer. If you could be more specific in your reference and in your questions, we would be happy to respond to you. If the correspondence to which you refer is from our Enforcement office, you might want to direct your inquiry to them.; Sincerely, Frank Berndt, Chief Counsel