Interpretation ID: aiam5137
Inc. P.O. Box 2450 1408 Courtesy Road High Point
NC 27261;
"Dear Mr. Marion: This responds to your letter asking whether there ha been any consideration given to excluding 'non-route-type' school buses from Standard No. 131's requirement that school buses be equipped with a stop signal arm. You stated that, as a manufacturer of school bus bodies, you are getting numerous questions regarding the installation of stop arms on school buses not used on route service. According to your letter, a number of schools across the U.S. purchase school buses, paint them a color other than yellow, and use them exclusively for athletic trips. You stated that these buses pick up at the school and travel to another school to unload, and do not make stops for loading or unloading along the way and in no way attempt to control traffic. You stated that the purchasers of these school buses are concerned about paying for stop arms which are never used. As you know, Federal Motor Vehicle Safety Standard No. 131, School Bus Pedestrian Safety Devices, is a new Federal motor vehicle safety standard which requires all new school buses to be equipped with a stop signal arm. The purpose of the requirement is to reduce deaths and injuries by minimizing the likelihood of vehicles passing a stopped school bus and striking pedestrians in the vicinity of the bus. To answer your specific question, this agency has not considered whether 'non- route-type' school buses should be excluded from Standard No. 131's requirement for a stop signal arm. I note that this issue was not raised in the comments on our notice of proposed rulemaking. We do appreciate the concern of a purchaser about paying for safety equipment that he or she believes will never be used. However, the limited information provided in your letter does not provide a basis for concluding that we should consider changing the standard. We do not know how many school buses are used exclusively or primarily for 'non-route-type' service, although we assume the number is small. Further, it would appear that there would be occasion to use stop signal arms for some school buses used for such service. For example, these safety devices might be used while loading and unloading students when the school bus is parked on a school driveway or a road near a school, if the school bus is used to transport students to activities at locations other than schools, or if the school bus is sometimes used as a replacement for out-of-service regular route school buses. I also note that, assuming that there is occasion to use stop signal arms for some school buses which are primarily used for non-route service, it is not clear how the agency would distinguish, for purposes of a regulation, which school buses should be excluded from the requirement for stop arms. I hope this information is helpful. Sincerely, Barry Felrice Associate Administrator for Rulemaking";