Interpretation ID: nht79-1.22

DATE: 12/19/79

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Sheller-Globe Corporation

TITLE: FMVSS INTERPRETATION

TEXT:

December 19, 1979

NOA-30

Mr. R. M. Premo Director, Vehicle Safety Activities Sheller-Globe Corporation 3555 St. Johns Road Lima, Ohio 45804

Dear Mr. Premo:

This responds to your November 12, 1979, letter asking whether several joints in your school bus must comply with Standard No. 221, School Bus Body Joint Strength. All of the joints concern what you have called maintenance access panels.

As you are aware, the agency has discovered through its compliance testing that most school bus manufacturers have taken advantage of the maintenance access panel exemption from the standard. The result is that many joints in school buses are not as secure as they should be and, during an accident, might result in injury to children being transported in those buses. The agency is very concerned about this practice and is considering methods of limiting the maintenance access panel exemption.

Your letter asks the agency to consider the fact that the panels whose joints you are questioning are plastic and not metal. Therefore, you conclude that the edges are not sharp, and even if the panels come unfastened in an accident, their edges will not be likely to injure the occupants of your buses.

The standard establishes joint strength tests that apply uniformly to all joints regardless of the material used in the panel. While it may be true that plastic panels are less likely to injure occupants of buses when a panel becomes disconnected during an accident, Standard No. 221 addresses other safety areas beyond preventing the sharp edges of panels from cutting occupants. Joint strength is necessary for the vehicle integrity during accidents. This is as important as preventing cutting edges from panels. Accordingly, the agency will continue to subject all joints falling within the parameters of the standard to the requirements of the standard without regard to the material used in a panel.

With respect to the questions posed in your letter, you first ask whether the right and left hand windshield pillar covers must comply with the standard. You indicate that a hose runs behind one pillar cover and a cable control runs behind the other. The agency has indicated that the installation of a wire, hose or cable behind a wall does not make that wall a maintenance access panel. Accordingly, the agency concludes that the joints connecting the pillar cover panel are subject to the standard.

Your questions 2, 4, and 5 refer to panels that cover motors which you indicate must be serviced. The motors include the windshield wiper and heater motors. The agency is unable to determine from your pictures and sketches whether all of the joints surrounding these motors are subject to the standard. The joints connecting panels that must be removed for routine servicing of a vehicle's motors would not be considered as joints subject to the standard. However, these joints must be the minimum necessary for routine servicing of the motors. In compliance testing your vehicles, the agency will only exempt those joints that are necessary for routine servicing. We will not exempt adjacent panel joints simply because wires run beneath them.

In your third question you describe a dash trim panel that covers a wiring harness, some chassis cowl mounting bolts, and an entrance door cable. The agency needs more information to make a formal determination with respect to this panel and its joints. Our inclination based upon the information that you have presented is that these would be joints subject to the standard, because the removal of this panel is not required for routine maintenance.

Your final question asks whether the entrance door control cover must comply with the standard. You state only that must be removed to remove the dash trim panel. As we stated in the last paragraph, we believe that the dash trim panel joints may be required to comply with the standard. If this is the case, it may also be necessary for the door control cover joints to comply with the standard. The key factor in determining whether this panel's joints must comply with the requirement is whether the panel must be removed for routine maintenance. You have not proven such a need in your letter, concerning the need for these joints to comply with the standard.

Sincerely,

Frank Berndt Chief Counsel

November 12, 1979

Mr. Frank Berndt, Chief Counsel Office of the Chief Counsel U.S. Department of Transportation 400 Seventh Street, S.W. Washington, D.C. 20590

Dear Mr. Berndt:

The purpose of this letter is to obtain rulings that the seven parts listed below will comply with the exclusions allowed under S.4 of FMVSS 221 as they relate to the need for maintenance.

The parts are made from a flexible plastic material called polypropolene. The purpose is to cover many unsightly conditons of components required to be installed, some due to assembly of the body to the chassis, and others required by either federal or state regulations. It is our opinion that a very important secondary purpose is accomplished in that due to the flexibility and rounded corners of the plastic parts, many edges and corners of steel parts will gain additional protection. Additionally if the parts were to come loose during an accident, which is unlikely unless of a violent type, they could do little, if any, physical injury due to the flexibility of the material.

(1) Right-hand & Left-hand Windshield Pillar Covers

(a) The left-hand pillar requires the running of an air or vacuum line to the top of the windshield to operate a mechanical wig wag signal that informs the driver of a drop in air pressure in the brake system and is required in some states.

(b) The right-hand pillar has a cable control anounced to the windshield pillar that connects the driver operated door control to the mechanism at the top of the doors to operate the entrance doors.

(2) Left-hand Dash Trim

This part must be removed to service the windshield wiper motor, mechanism and wiring.

(3) Dash Trim - Center.

Covers a wiring harness, some of the body to chassis cowl mounting bolts that need to be retightened occasionally and entrance door control cable.

(4) Right-hand Dash Trim

Requires removal to service the right-hand windshield wiper motor, mechanism, wiring for the windshield motor, right-hand heater and door control cable.

(5) Right-hand Heater Cover

Must be removed to service the motors, blower, and heater cores.

(6) Entrance Door Control Cover

This covers the body of the door control which houses the switches that operate a part of the roof light warning system and stepwell light. It also must be removed along with the door control assembly in order to remove the center dash trim.

Our planning is to use these parts in production January 1980, but final decision will be based upon your rulings.

We definitely are of the opinion this adds to the enterior safety as well as appearance, but requires decisions before the expense of tooling for these parts.

A photograph is enclosed showing a prototype with the subject parts installed.

Due to tooling lead time and present date, your prompt reply is requested.

Very truly yours,

R. M. Premo - Director Vehicle Safety Activities

RMP:cr Enclosures (2)

Photographs Dwg. #LO-21782-D