Interpretation ID: aiam3653
Manager
Engineering Services
Blue Bird Body Company
P.O. Box 937
Fort Valley
GA 31030;
Dear Mr. Turner: This is in reply to your letter of December 7, 1982, to Mr. Vinson o this office asking for an interpretation of Motor Vehicle Safety Standard No. 108 with respect to a new option for school buses permitted by Wisconsin. This option would allow two additional red lamps, front and rear, as a supplement to the red warning lamp system required by paragraph S4.1.4(a) of the standard.; As a general rule, supplemental lighting is permitted by Standard No 108 as long as it does not 'impair the effectiveness of lighting equipment' required by the standard (paragraph S4.1.3). In our opinion, the separate lamps that would be permitted by Wisconsin on the front of the school bus, between the bottom of the windshield and the top of the highest headlamp, would not impair the effectiveness of the front lighting equipment. The lamps on the rear, however, according to Wisconsin, could be incorporated 'in an existing lamp' provided that such incorporation 'shall not interfere with or override the existing unit's function.' We believe that the language both of Standard No. 108 and the Wisconsin specification would effectively prohibit incorporation of the warning lamp into the stop lamp of the school bus. However, we believe that this language would allow its combination with the tail lamp, or its addition as a separate lamp.; We trust that this is responsive to your request. Sincerely, Frank Berndt, Chief Counsel