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Interpretation ID: GF000167

    [ ]


    Dear [ ]:

    This responds to your letter dated December 29, 2004, asking whether an LED lighting design concept for school buses being contemplated by your company could be used to comply with applicable Federal regulations.

    Before I address your questions, I note that you requested confidential treatment of your letter. During a February 15, 2005, telephone call, George Feygin of my staff explained to you that the National Highway Traffic Safety Administration (NHTSA) does not respond to confidential requests for an interpretation because our interpretations are made publicly available. However, NHTSA is able to keep your identity and that of your company confidential. You agreed to this approach. Thus, I agree to keep your name and the name of your company confidential. All information in bold brackets [ ] will be kept confidential from the public. Your incoming interpretation request will be redacted before being made publicly available.

    By way of background, NHTSA does not provide approvals of motor vehicles or motor vehicle equipment. Under 49 U.S.C. Chapter 301, manufacturers are required to certify that their vehicles and equipment meet applicable requirements.

    In your letter, you describe a dual function school bus signal lamp that flashes amber when the bus is slowing down and red when it has stopped. You indicate that the lamp meets all "SAE light output requirements". You ask whether using one lighting device for both functions is permitted by our standards.

    The Federal motor vehicle safety standard (FMVSS) applicable to school bus signal lamps is FMVSS No. 108, Lamps, Reflective Devices, and Associated Equipment. Specifically, S5.1.4 of FMVSS No. 108 requires each school bus to be equipped with a system of four red signal lamps, designed to conform to SAE Standard J887, School Bus Red Signal Lamps, July 1964, or four red and four amber signal lamps designed to conform to the same SAE standard (with certain exceptions for the amber lamps).

    Additionally, S5.1.4(b) requires, in pertinent part, that if the bus is equipped with four amber lamps, their candlepower must be at least 2 1/2 times that specified for red signal lamps. Further, the amber signal lamps can be activated only by manual or foot operation, and must automatically deactivate when the red signal lamps automatically activate because the bus entrance door is opened.

    While the language of FMVSS No. 108 contemplates separate sets of red and amber signal lamps, it is our opinion that dual function school bus signal lamps that flash both red and amber could be used to meet the standards requirements. We note that S5.4 of FMVSS No. 108 permits combining two or more lamps if the requirements for each lamp are met. In this case, the following requirements of S5.1.4(b) would need to be satisfied:

    1. The candlepower of the amber lamp must be at least 2 1/2 times that specified for the red signal lamp in SAE Standard J887, School Bus Red Signal Lamps, July 1964.
    2. The amber signal lamps can activate only by manual or foot operation
    3. The amber lamps must automatically deactivate when the bus entrance door is opened
    4. 4) The red lamps must automatically activate when the bus entrance door is opened

    We also note that under SAE J887, the portion of the lamp that emits red light and the portion of the lamp that emits amber light must each provide an effective projected illuminated area of not less than 19 sq. inches.

    I hope you find this information helpful. If you need further assistance, please contact George Feygin of my staff at this address or at (202) 366-2992.

    Sincerely,

    /s

    Jacqueline Glassman
    Chief Counsel

    ref:108
    d.3/17/05