Interpretation ID: aiam2553
Manager
Engineering Services
Blue Bird Body Company
P.O. Box 937
Fort Valley
GA 31030;
Dear Mr. Milby: This is in reply to your letter of March 29, 1977, asking two question about the use of strobe lamps on school buses.; Your first question is whether it is 'legal to install strobe typ warning lamps on school buses?' The answer is yes provided such lamps meet the specific performance requirements in S4.1.4 which incorporates SAE Standard J887 'School Bus Red Signal Lamps.'; You also reference 'certification from our vendor. . . that his syste meets FMVSS if installed according to his instructions.' You have asked if this letter from your vendor is 'adequate documentation upon which we could certify that a bus with such a system meets FMVSS 108?' In an earlier opinion letter on this subject (to Yankee Metal Products Corporation of April 12, 1976) we opined opinion by a professional engineer indicating compliance of a strobe lamp design with SAE J887 provided a basis upon which Yankee could certify that its system meets Standard No. 108. Since you did not enclose the letter from your vendor we cannot comment upon it. However the National Traffic and Motor Vehicle Safety Act requires that a manufacturer exercise due care in insuring that its certification is not false and misleading in a material respect, and you should exercise the same care in this instance that you do with respect to insuring compliance of other items of lighting devices with which your buses are equipped.; Yours truly, Frank Berndt, Acting Chief Counsel