Interpretation ID: aiam2027
Consultant
Transportation
Traffic & Safety
Superintendent of Public Instruction
Old Capitol Bldg.
Olympia
WA 98504;
Dear Mr. Toner: This is in reply to your letter of July 15, 1975, to Mr. J. E. Leysat of this agency asking whether the State of Washington's proposed school bus light warning system conflicts with S4.1.4(b)(ii) of Federal Motor Vehicle Safety Standard No. 108.; That section requires an eight lamp signal system to be wired 'so tha the amber signal lamps are activated only by manual or foot operation, and if activated, are automatically deactivated and red signal lamps automatically activated when the bus entrance door is opened.' Under the system Washington proposes, when a school bus stops, a 'stop paddle sign' is extended by the operator, activating 'a switching system which will terminate the yellow flashing lights and start the red flashing lights,' before the door is opened.; Under the system you describe, the termination of the yellow lamps an activation of the red ones is dependent upon the operator extending the stop paddle sign. Should the operator forget to extend the sign, it does not appear that the system required by S4.1.4 would operate automatically when the door is opened. We therefore conclude that in order to meet S4.1.4 your school buses must be equipped with an override switch that would deactivate the amber lamps and activate the red ones when the door is opened, in the event that the stop paddle sign has not been extended.; Sincerely, Frank A. Berndt, Acting Chief Counsel