ID: 1987y

Mr. Michael E. Kastner
National Truck Equipment
Association--Washington Office
1350 New York Avenue, N.W., Suite 800
Washington, D.C. 20005-4797

Dear Mr. Kastner:

Thank you for your letter to Secretary Skinner concerning the National Highway Traffic Safety Administration's (NHTSA's) actions to extend certain Federal Motor Vehicle Safety Standards (FMVSS's) to light trucks and vans. The Secretary has asked me to reply.

Your letter was especially concerned with NHTSA's November 1987 amendment to FMVSS 204, Steering Control Rearward Displacement, and our denial of NTEA's petition for reconsideration of that rule. I regret that I am unable to respond to your comments at this time. As you know, the Department and NTEA are presently involved in litigation concerning those actions. In view of the litigation, we feel it would be inappropriate to address your comments in this letter.

We appreciate your interest in informing the Department of your views. I can assure you that Secretary Skinner is actively interested in each of the letters he receives regarding NHTSA's mission to improve motor vehicle safety. Let me assure you also that the potential impacts on small businesses is one of our concerns in each of our rulemaking actions.

A copy of your letter, and this response, will be placed in NHTSA's docket section.

Sincerely,

Jeffrey R. Miller Acting Administrator ref:204 d:8/22/89

ID: 19882.drn

Pastor Carlo DeStefano
Fairwinds Baptist Church
801 Seymour Road
Bear, DE 19701

Dear Pastor DeStefano:

This responds to your April 14, 1999, letter requesting information on Federal statutes governing school bus safety. Dorothy Nakama of my staff spoke to your secretary, who informed us that your church operates Fairwinds Christian School, which teaches students from kindergarten through twelfth grade. Ms. Nakama was informed that you seek information about the school bus safety laws administered by the National Highway Traffic Safety Administration (NHTSA) to determine what your responsibilities are when transporting your students.

I am pleased to provide the following information. NHTSA is authorized to issue and enforce Federal motor vehicle safety standards applicable to new motor vehicles. Our statute at 49 U.S.C. 30112 requires any person selling or leasing a new vehicle to sell or lease a vehicle that meets all applicable standards. Accordingly, persons selling or leasing a new "school bus" must sell or lease a vehicle that meets the safety standards applicable to school buses. Our statute defines a "schoolbus" as any vehicle that is designed for carrying a driver and more than 10 passengers and which, NHTSA decides, is likely to be "used significantly" to transport "preprimary, primary, and secondary" students to or from school or related events. 49 U.S.C. 30125. By regulation, the capacity threshold for school buses corresponds to that of buses -- vehicles designed for carrying more than ten (10) persons. For example, a 15-person van that is likely to be used significantly to transport students is a "school bus."

Our statute thus regulates primarily manufacturers and sellers of new school buses. Any person selling a new school bus must sell a vehicle that is certified as meeting our school bus standards. Conventional buses (including 15-passenger vans) are not certified as doing so, and thus cannot be sold, as new vehicles, under circumstances where they are likely to be used to carry students on a regular basis.

In general, our school bus safety statute does not regulate school bus users. Instead, each State has the authority to set its own standards regarding the use of motor vehicles, including school buses. You should check Delaware law to see what your State law requires when your private school transports its students. For information on Delaware's requirements, you can contact Delaware's State Director of Pupil Transportation:

Mr. Ronald Love, State Supervisor, School Transportation
Delaware Department of Education
P. O. Box 1402
Dover, DE 19903
Telephone: (302) 739-4696

In closing, we wish to emphasize that school buses are one of the safest forms of transportation in this country, and that we therefore strongly recommend that all buses that are used to transport school children be certified as meeting NHTSA's school bus safety standards. Further, using buses that do not meet NHTSA's school bus standards to transport students could result in increased liability in the event of a crash. Since such liability would be determined by State law, you may wish to consult with your attorney and insurance carrier for advice on this issue.

I hope this information is helpful. For more information about the safety features of a school bus, I am enclosing NHTSA's publication: "School Bus Safety: Safe Passage for America's Children." If you have any further questions please feel free to contact Dorothy Nakama at this address or by telephone at (202) 366-2992.

Sincerely,
Frank Seales, Jr.
Chief Counsel
Enclosure
ref:VSA#571.3
d.5/25/99

ID: 19883.wkm

Tim Broten, President
Skiddd Wheel Indicator
Box 129
Starbuck, Mb.
ROG 2PO
CANADA

Dear Mr. Broten:

Your letter to Mr. Ron Evenson, State Director, Office of Motor Carrier Safety, Bismarck, North Dakota, was forwarded to this agency for reply.

You stated in your letter that your company produces the Skiddd wheel lock indicator that is described as a strip of special nylon plastic that is attached to the wheel stud of a truck. The Skiddd protrudes out from the wheel about two inches, which allows the driver to see from his rear view mirror whether the wheel is turning. The intent is to permit the driver to determine from the truck cab whether the wheels are in fact turning or whether one or more of them are skidding. You asked for a "letter of approval" to indicate that the Skiddd indicator complies with applicable safety standards.

By way of background information, the National Highway Traffic Safety Administration (NHTSA) has the statutory authority to issue Federal motor vehicle safety standards (FMVSS) applicable to new motor vehicles and new items of motor vehicle equipment. Federal law establishes a self-certification system under which motor vehicle and equipment manufacturers themselves certify that their products comply with all applicable FMVSSs. For that reason, NHTSA neither tests, approves, disapproves, endorses, nor grants letters of approval of products prior to their introduction into the retail market. Rather, we enforce compliance with the FMVSSs by purchasing vehicles and equipment and testing them. We also investigate safety-related defects.

Turning now to the Skiddd wheel lock indicator, we would classify it as an item of motor vehicle equipment, defined in 49 U.S. Code (U.S.C.) 30102(a)(7)(B) as any "part or component manufactured or sold for replacement or improvement of a system, part, or component, or as an accessory or addition to a motor vehicle." Specifically, the Skiddd wheel lock indicator is an accessory if it meets the following criteria:

a. A substantial portion of its expected uses are related to the operation or maintenance of motor vehicles; and

b. It is purchased or otherwise acquired, and principally used by ordinary users of motor vehicles.

After reviewing your letter and its enclosed product brochure, we conclude that the Skiddd wheel lock indicator is an accessory. It was designed with the expectation that a substantial portion of its expected use will be with motor vehicles. Further, the pictures of the Skiddd in the brochure make it clear that the wheel lockup indicator is intended to be purchased and principally used by ordinary users of motor vehicles, mostly truck drivers, to continuously monitor whether their wheels are turning properly.

While the Skiddd wheel lock indicator is a motor vehicle accessory, NHTSA has not issued any FMVSSs establishing performance standards applicable to this product. However, the manufacturer, whether you or a licensee, is subject to the requirements of 49 U.S.C. 30118 - 30121 (copies enclosed) which set forth the recall and remedy procedures for products with defects related to motor vehicle safety. Thus, if NHTSA or the manufacturer determines that the product contains a safety-related defect, the manufacturer is responsible for notifying purchasers of the defective equipment and for remedying the problem free of charge to the consumer.

Additionally, 49 U.S.C. 30122 (copy enclosed) provides that a manufacturer, distributor, dealer, or vehicle repair business may not knowingly "make inoperative" any device or element of design installed on or in a motor vehicle in accordance with any FMVSS. Therefore, the Skiddd could not be installed by one of those entities if such use would adversely affect the compliance of a vehicle with any FMVSS. This provision does not apply, however, to equipment attached to or installed on or in a vehicle by the vehicle owner.

I note that the Department's Office of Motor Carrier Safety has jurisdiction over interstate motor carriers operating in the U.S. On August 18, 1999, the Vehicle and Operations Division of that agency responded to your inquiry about using the Skiddd indicator on commercial motor vehicles. We have coordinated this response through the Acting Director of the Office of Motor Carrier Safety.

For your further information, I am enclosing a fact sheet we prepared entitled Information for New Manufacturers of Motor Vehicles and Motor Vehicle Equipment, and Where to Obtain NHTSA's Safety Standards and Regulations.

I hope this information is helpful to you. If you have any questions or need additional information, feel free to contact Edward Glancy of my staff at this address, by telephone at (202) 366-2992, or by fax at (202) 366-3820.

Sincerely,
Frank Seales, Jr.
Chief Counsel
Enclosures

cc: Mr. Ronald O. Evenson
State Director
Office of Motor Carrier Safety
1471 Interstate Loop
Bismarck, ND 58501

ref:119
d.11/23/99

ID: 19884.ztv

Mr. Ron Woodward, P.E.
Section Supervisor Optics & Adv. Eng.
Federal Mogul
2513 58^th Street
Hampton, VA 23661

Dear Mr. Woodward:

This is in reply to your letter of April 19, 1999, requesting an interpretation of Federal Motor Vehicle Safety Standard No. 108 Lamps, Reflective Devices and Associated Equipment as it applies to a proposed horizontal alignment system for use with visual/optical aim headlamps.

Paragraph S7.8.2.1(c) of Standard No. 108 states that "A visually/optically aimable headlamp that has a lower beam shall not have a horizontal adjustment mechanism unless such mechanism meets the requirements of paragraph S7.8.5.2 of this standard." You reference previous interpretations of this office which state "that disabled horizontal adjusters are acceptable [i.e., are not horizontal aim mechanisms within the meaning of the phrase]," that "certain types of anti-tamper screws are not permitted" ("ones that can be driven in one direction"), but not all types of such screws, and "exposed screw heads were also rejected because pliers could be used to rotate the screw."

You have enclosed a drawing showing a horizontal alignment system that you propose to use. It "would be used during manufacturing to achieve proper mechanical alignment of the mounting surface and lamp optical system and is not meant to be adjustable after manufacture." The drawing you enclose shows both a plan and section view of your system. There is an "external shroud [which] prevents adjustment by wrenches and pliers." There is also a center section described as "center anti-tamper post [which] prevents entry of standard Torx driver bit, screw driver, & Allen wrench." You ask whether we would regard this as a horizontal adjustment mechanism as prohibited by S7.8.2.1(c).

Yes, we would regard this design as a horizontal aim mechanism within the meaning of S7.8.2.1(c)(and impermissible because it does not meet S7.8.5.2). Although the center anti-tamper post prevents entry of a standard Torx driver bit, non-standard Torx driver bits are readily available which would defeat your intent that the horizontal alignment not be adjustable after manufacture. Specifically, SK Drive Tamper-Proof Torx Bits are available through internet web sites, if not tool jobbers and mobile tool sales outlets, and these are intended to fit the center anti-tamper post and allow entry.

If you have any questions, you may phone Taylor Vinson of this Office (202-366-5263).

Sincerely,
Frank Seales, Jr.
Chief Counsel
ref:108
d.6/28/99

ID: 19886.ztv

David H. Coburn, Esq.
Steptoe & Johnson LLP
1330 Connecticut Avenue, NW
Washington, DC 20036-1795

Re: Request for Clarification

Dear Mr. Coburn:

This is in reply to your letter of April 16, 1999, seeking a confirmation that a previous interpretation of Federal Motor Vehicle Safety Standard No. 108 remains valid.

The interpretation is one that we sent your client, Baran Advanced Technologies, Ltd., on September 7, 1993. In that letter, we informed Baran that we did not believe that a device which activates a vehicle's hazard warning system upon sensing a sudden release of the accelerator pedal would impair the effectiveness of the stop, tail, and turn signal lamps required by Standard No. 108, assuming that the device is not activated under normal stopping conditions, that it is automatically deactivated when the brake pedal is applied, that manual deactivation is not required, and that the device would be overriden by manual activation of the turn signal lamps.

Regrettably, I cannot confirm that this interpretation remains valid. Our earlier interpretation did not consider the effect of the device upon the hazard warning signal itself. Since 1993, we have come to the conclusion that use of required lighting equipment for other than its original purpose may compromise and reduce its safety effectiveness. As we said in 1996,

It is important that the integrity of the required signal lamps be maintained, and that auxiliary signal lamps not detract attention from the messages that the required signal lamps are sending. A vehicle signaling system must be as simple and as unambiguous as possible to others who share the roadway if traffic is to proceed in a safe and orderly fashion. (61 FR 65516)

See also our Statement of Policy published in the Federal Register on November 4, 1998 (63 FR 59482, copy enclosed).

We believe that a hazard warning system should not be used for the auxiliary purpose of indicating sudden accelerator release, a signal that bears no relationship to a hazard warning signal and one which could create confusion were the hazard warning signal used for an unrelated purpose. We believe that our 1993 interpretation was superseded by our subsequent policy statement, and therefore reverse it and conclude that S5.1.3 prohibits the system as described.

If you have any questions, you may call Taylor Vinson (202-366-5263).

Sincerely,
Frank Seales, Jr.
Chief Counsel
Enclosure
ref.108
d.8/6/99

ID: 1988y

Mr. Dan Trexler
Specifications Engineer
Thomas Built Buses, Inc.
P.O. Box 2450
High Point, NC 27261

Dear Mr. Trexler:

This is in reply to your letter of May 8, l989, to the former Chief Counsel of this agency, Erika Jones. You have received requests "to install a master electrical disconnect switch on many buses." When the switch is turned to the "off" position "it renders inoperative the warning signals (to the driver) required by FMVSS l05, 121 and 217. It also inactivates the hazard warning flasher required by FMVSS l08." You ask whether installation of the switch would constitute a noncompliance, or a "safety related hazard." if it is accessible to the seated driver, or if remotely located in the battery or engine compartment, without ready access to the driver.

Although you have not explained the purpose of such a device, we understand that a battery disconnect switch of this nature is deemed desirable by many bus owners to prevent drains on the battery when the bus is at rest. When the switch is activated, the bus cannot be started and driven because electric power is not available. Under this circumstance we do not believe that the switch either creates a noncompliance with any of the standards listed, nor constitutes a safety related defect, regardless of its location. When the bus is in operation the warning systems of the standards are not affected. The possibility of inadvertent activation when the bus is in use does not constitute a defect in performance, construction, components, or materials such as to create a safety related defect. To forestall any possibility of inadvertent activation, however, you may find it preferable to locate the switch away from the driver.

We understand that a purpose of this switch is to reduce the likelihood of fire after accidents in which there has been fuel spillage. In this circumstance, it is likely that the bus would be positioned either in the roadway or adjacent to it. Safety would be enhanced if the hazard warning signal power source were separate from the batteries inactivated by the disconnect switch, so that these warning lamps could continue to operate.

Sincerely,

Stephen P. Wood Acting Chief Counsel / ref:VSA#l04#l08#l2l#2l7 d:8/30/89

ID: 19891.drn

Mr. Dennis Seavey
Plus Time New Hampshire
160 Dover Road, Suite One
Chichester, NH 93234

Dear Mr. Seavey:

This responds to your letter asking about our August 8, 1998, interpretation to Mr. Terry L. Voy, School Transportation Consultant for the Iowa Department of Education, concerning our school bus regulations.

In the letter to Mr. Voy, we explained that persons selling a new bus to a daycare facility must sell a "school bus" if the bus will be significantly used to transport school children to or from school or related events. As to whether a bus is "used significantly" for such use, we told Mr. Voy that regular use of a bus to pick up students from school five days a week would constitute "significant use" as a school bus. We also stated in that letter that "regular use on alternate days would be 'significant.'"

You ask about the latter statement, as to whether transporting school-aged children to and/or from a child care facility and school three days a week (Monday, Wednesday, and Friday) constitutes "significant use" as a school bus. You also ask if we would consider the bus to be "significantly" used for school transportation if it were used to take children to and/or from school on Tuesdays and Thursdays.

Our answer is that regular use of the vehicle to transport school children to or from school on Mondays, Wednesdays, and Fridays, or on Tuesdays and Thursdays, is "significant use" of the vehicle for school transportation. We would also consider transportation provided to or from school on any two days during a week to be regular use and therefore "significant."

As you are aware, the National Highway Traffic Safety Administration's (NHTSA) safety standards directly regulate the manufacture and sale of new motor vehicles, not their use. Each state has the authority to set its own standards regarding use of motor vehicles, including school buses. Please check with the appropriate New Hampshire officials to see if any State law regulates how New Hampshire school children must be transported between their school and after school programs. For information on New Hampshire's requirements, you may contact New Hampshire's State Director of Pupil Transportation:

Ms. Bethia LaMarca, Pupil Transportation Supervisor
New Hampshire Department of Safety
10 Hazen Drive
Concord, NH 03305
Telephone: (603) 271-1999

In closing, we wish to emphasize that school buses are one of the safest forms of transportation in this country, and that we therefore strongly recommend that all buses that are used to transport school children be certified as meeting NHTSA's school bus safety standards. Further, using 15-person vans that do not meet NHTSA's school bus standards to transport students could result in increased liability in the event of a crash. Since such liability would be determined by State law, you may wish to consult with your attorney and insurance carrier for advice on this issue.

I hope this information is helpful. I am enclosing NHTSA's publication: "School Bus Safety: Safe Passage for America's Children" that describes the safety features of a school bus. I am also enclosing NHTSA's February 1999 "Guideline for the Safe Transportation of Pre-school Age Children in School Buses." If you have any further questions please feel free to contact Dorothy Nakama of my staff at this address or by telephone at (202) 366-2992.

Sincerely,
Frank Seales, Jr.
Chief Counsel
Enclosures
ref:VSA#571.3
d.5/20/99

ID: 1989y

Mr. Bradley J. Baker
President
Classic Manufacturing, Inc.
21900 U.S. 12
Sturgis, MI 49091

Dear Mr. Baker:

This is in reply to your letter to Taylor Vinson of this Office, with reference to a product your company manufactures, a "car dolly used to tow a vehicle behind motor homes." You question whether the dolly is a motor vehicle, and if so, whether identification lamps are necessary for it. I regret the delay in responding.

The car dolly appears to be a vehicle drawn by mechanical power manufactured primarily for use on the public roads, and thus a "motor vehicle" subject to the jurisdiction of this agency. Specifically, it would be a "trailer", since it is a motor vehicle without motive power, designed for carrying property and for being drawn by another motor vehicle. Federal Motor Vehicle Safety Standard No. l08, Lamps, Reflective Devices, and Associated Equipment, requires identification lamps on all trailers whose overall width is 80 inches or more. Therefore, if the overall width of your dolly is less than 80 inches, it need not be equipped with identification lamps.

Sincerely,

Stephen P. Wood Acting Chief Counsel

/ Ref:l08 d:8/3l/89

ID: 1990y

Thomas A. Coz, Esq.
Senior Attorney
North American Van Lines
Law Department
P.O. Box 988
Fort Wayne, IN 46801-0988

Dear Mr. Coz:

This is in reply to your letter of April 28, l989, with respect to the legality under Standard No. l08 of supplemental lighting devices that North American Van Lines has installed on some of its trailers. To assist us in answering your question, you have enclosed a photograph of a trailer retrofitted with the supplemental devices, and a videocassette. However, the "Final Specs" sheets referenced in your letter were not enclosed.

The lamps in question are stop lamps/turn signal lamps which are mounted above the maximum mounting heights specified in Standard No. l08. You believe that this is permissible because they are supplemental to the original equipment stop and turn signal lamps which are mounted within the limits specified in the standard. However, the Department of California Highway Patrol has informed you that this agency does not differentiate between original and supplemental equipment, and requires that both original and supplemental lighting equipment must conform to the mounting requirements.

We are not aware of the basis of the California opinion. The only requirement of Standard No. l08 for supplemental lighting equipment on vehicles prior to their first purchase for purposes other than resale is the restraint of paragraph S5.l.3 that they not impair the effectiveness of the lighting equipment required by the standard.

Retrofit by North American Van Lines itself of its own vehicles after the first purchase for purposes other than resale is permissible under Federal law. However, if the retrofit were performed by a manufacturer, dealer, distributor, or motor vehicle repair business, the operation would be subject to the restraint of Section 108(a)(2)(A) of the National Traffic and Motor Vehicle Safety Act (l5 U.S.C. 1397(a)(2)(A)) that it not render inoperative, in whole or in part, lighting equipment installed in accordance with Standard No. l08. Subject to these constraints, a mounting height that exceeds the maximum specified by Standard No. l08 is permissible for supplemental lighting equipment. We interpret "partially inoperative" as also meaning "partially ineffective". The location of your lamps as shown in the photograph you enclosed does not appear to "render inoperative" any other lighting device or affect its effectiveness.

We note that the retrofitted trailer in the videocassette does not appear to be equipped with the identification lamps required by Standard No. l08. Further, unless the clearance lamps are combined with the supplemental stop/turn signals in both the videocassette and the photograph you enclosed, they too appear to be missing. If the clearance lamps are combined with the supplementary lamps, care should be taken that the supplementary lamps do not "render inoperative" the clearance lamps. Although, as noted above, the Act permits an owner to modify his vehicle in a nonconforming manner, the operation of your interstate highway trailer is subject to the regulations of the Bureau of Motor Carrier Safety, Federal Highway Administration, which require that identification and clearance lamps be provided for these trailers.

We are returning your videocassette.

Sincerely,

Stephen P. Wood Acting Chief Counsel

Enclosure

ref:VSA Sec. l08 d:8/24/89

ID: 19914.drn

Matt Boley, Executive Director
Mary J. Treglia Community House
900 Jennings St.
Sioux City, IA 51105

Dear Mr. Boley:

This responds to your request for information regarding transportation of school children from school to your facility and during the school day. You write that, in addition to providing services for school children, you offer adult programs such as English as a Second Language and Citizenship classes, as well as senior citizen and health outreach programs. In a telephone conversation with Dorothy Nakama of my staff, you stated that you regularly provide transportation from school for the school children and that you are using 15-person vans to transport both the adults in your program and the children.

Some background information would be helpful in answering your question. The National Highway Traffic Safety Administration ( NHTSA) is authorized to issue and enforce Federal motor vehicle safety standards applicable to new motor vehicles. Our statute at 49 U.S.C. 30112 requires any person selling or leasing a new vehicle to sell or lease a vehicle that meets all applicable standards. Accordingly, persons selling or leasing a new "school bus" must sell or lease a vehicle that meets the safety standards applicable to school buses.

Our statute defines a "schoolbus" as any vehicle that is designed for carrying a driver and more than 10 passengers and which, NHTSA decides, is likely to be "used significantly" to transport "preprimary, primary, and secondary" students to or from school or related events. 49 U.S.C. 30125. By regulation, the capacity threshold for school buses corresponds to that of buses -- vehicles designed for carrying more than ten (10) persons. For example, a 15-person van that is likely to be used significantly to transport students is a "school bus."

In recent interpretation letters to NHTSA, the agency was asked to address situations where non-educational institutions (such as day care centers) are procuring buses to transport children to or from schools. When a day care center will be using a bus to transport school children "to or from school" or school-related activities on a regular (non-occasional) basis, the dealer who sells or leases the new bus to the center must sell or lease a "school bus." These may include van-based vehicles, completed by school bus manufacturers, that are certified to those standards. In contrast, if a day care center will not use the new bus to take children to or from school or school-related activities, the dealer is not required to sell or lease a school bus.

One of those letters involved a dealer selling a new 15-passenger van to a child care facility which planned to significantly use the van for school transportation. The letter is dated July 23, 1998, to Mr. Don Cote of Northside Ford in San Antonio, Texas (copy enclosed). In that letter, we explained that a dealer selling or leasing a new van for such use must sell or lease only buses that meet Federal motor vehicle safety standards for school buses, even when the purchaser is a child care facility.⁽¹⁾

Because our regulations apply only to the manufacture and sale of new motor vehicles, we do not prohibit centers from using their large vans to transport school children even when the vehicles do not meet Federal school bus safety standards. However, each State has the authority to set its own standards regarding the use of motor vehicles, including school buses, so you should also check Iowa law to see if there are regulations about how your center must transport school children.

Further, we wish to emphasize that school buses are one of the safest forms of transportation in this country, and that we therefore strongly recommend that all buses that are used to transport school children be certified as meeting NHTSA's school bus safety standards. In addition, using 15-person vans that do not meet NHTSA's school bus standards to transport students could result in increased liability in the event of a crash. Since such liability would be determined by State law, you may wish to consult with your attorney and insurance carrier for advice on this issue.

I hope this information is helpful. For more information about the safety features of a school bus, I am enclosing NHTSA's publication: "School Bus Safety: Safe Passage for America's Children." I am also enclosing NHTSA's February 1999 "Guideline for the Safe Transportation of Pre-school Age Children in School Buses." If you have any further questions please feel free to contact Dorothy Nakama of my staff at this address or by telephone at (202) 366-2992.

Sincerely,
Frank Seales, Jr.
Chief Counsel
Enclosures
ref:VSA#571.3 "school bus only"
d.6/10/99

1. Again, please note that NHTSA has never stated that day care facilities that provide only custodial care are "schools." NHTSA's laws do not affect new bus sales to child care facilities that are not significantly involved in transporting school aged children "to or from" school. The Cote letter could affect the facility if it is involved in transporting children to or from school.