Interpretation ID: 19257.drn

Mr. Robert L. Douglas
Director of Product Integrity
AmTran Corporation
P. O. Box 6000
Conway, AR 72033

Dear Mr. Douglas:

This responds to your request for interpretation of how to test a floor panel complex joint in a school bus, as AmTran is considering a new floor design. As explained below, the National Highway Traffic Safety Administration (NHTSA) will address this issue in a final rule amending Standard No. 221, School bus body joint strength.

As you are aware, in the FEDERAL REGISTER of November 5, 1998 (63 FR 59732), NHTSA published a final rule amending Standard No. 221. The final rule's effective date is May 5, 2001. The final rule addressed testing of curved or complex joints, such as that found in a school bus floor panel. NHTSA has received several petitions for reconsideration of the final rule to clarify test procedures for small, curved, and complex joints.

NHTSA is presently reviewing the petitions, and expects to issue another final rule on Standard No. 221 that will address the issues raised. Because the issue you raised in your letter was raised by the petitioners, we will address your question in our response to petitions for reconsideration that will be published some time in the future.

I hope this information is helpful. If you have any further questions, please feel free to contact Dorothy Nakama of my staff at this address or at (202) 366-2992.

Sincerely,
Frank Seales, Jr.
Chief Counsel
ref:221
d.7/10/00