Interpretation ID: aiam2784
Governor's Representative for Highway Safety
Illinois Department of Transportation
2300 South Dirksen Parkway
Springfield
IL 62764;
Dear Mr. Vieg: This is in reply to your letter of September 22, 1977, to th Administrator asking whether an Illinois standard applicable to school bus lighting is neither preempted by nor violates Federal Motor Vehicle Safety Standard No. 108, *Lamps, Reflective Devices, and Associated Equipment*.; Paragraph S4.1.4(b) (ii) of Standard No. 108 requires that: '>>>The [school bus signal lamp] system shall be wired so that th amber signal lamps are activated only by manual or foot operation and, if activated, are automatically deactivated and the red signal lamps automatically activated when the bus entrance door is opened.'<<<; Under the Illinois requirement (4.2.18.2) the amber signal lamps appea to be activated only by manual or foot control (4.2.18.2(d)), and are automatically deactivated when the bus entrance door is opened (4.2.18.2(e) and (f)). The red signal lamps are activated before the bus entrance door is opened (4.2.18.2(e)) and remain activated when the door is opened (4.2.18.2(f)). Thus, these portions of the Illinois requirement comply with Standard No. 108.; As for the remaining portions of 4.2.18.2, they dictate sequentia operational requirements of the 8-lamp system and stop arm (an item of equipment not required by Standard No. 108). To accomplish this operation, 4.2.18.2 requires that 'A separate circuit breaker and a master switch shall be provided for this signal system.' You have asked whether this is preempted by Standard No. 108.; The aspect of performance involved here is that of wiring requirement for school bus warning lamps. Standard No. 108 specifies the manner in which these lamps shall operate but it is silent as to the ways this performance shall be achieved. Therefore Illinois is not preempted from requiring a separate circuit breaker and master cylinder in school bus lighting systems, a specification which is one of good engineering practice and probably used as a matter of course by most school bus manufacturers.; Sincerely, Joseph J. Levin, Jr., Chief Counsel