Interpretation ID: 1985-04.18

TYPE: INTERPRETATION-NHTSA

DATE: 11/12/85

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Mr. Dennis Johnston

TITLE: FMVSS INTERPRETATION

TEXT:

November 12, 1985 Mr. Dennis Johnston Director, Pupil Transportation Office of School Standards Division of Elementary and Secondary Education Department of Education and Cultural Affairs 700 N. Illinois Pierre, South Dakota 57501 Dear Mr. Johnston: This is in reply to your letter of September 6, 1985, asking for an interpretation of the school bus lighting requirements of Federal Motor Vehicle Safety Standard No. 108. With the desire of warning motorists that a school bus is preparing to stop at a railroad crossing, you ask about the appropriateness of using the amber lights in a red and amber lamp school bus warning system for this purpose. The amber lamps would be activated 300 to 500 feet before the crossing, and remain activated when the bus had halted and its door had opened. However, the red lamps would remain deactivated, and not flash as they do when the bus has stopped to take on or discharge passengers. This would be accomplished by means of a switch which would be used only for the warning purpose described above. Paragraph S4.1.4(b)(2) of Standard No. 108 prescribes the method of operation of a red and amber school bus warning system: "(ii) The system shall be wired so that the amber 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." We interpret this as meaning that the system must operate in the prescribed manner whenever the bus entrance door is opened for whatever purpose, after the initial activation of the amber lamps. Therefore the system you describe is not permissible under Federal school bus lighting requirements. Sincerely, Original Signed By Erika Z. Jones Chief Counsel