Interpretation ID: GF007547

Mr. Scott Comisar
General Manager
Doran MFG, LLC
2851Massachusetts Ave.
Cincinnati, OH 45225

Dear Mr. Comisar:

This responds to your e-mail dated October 17, 2003, asking whether LED red and amber strobing warning lights "are safe to use on school buses."

By way of background, the National Highway Traffic Safety Administration (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. I note that this interpretation does not offer an opinion as to whether your particular lighting system is "safe." However, I will identify the federal regulation applicable to school bus signal lamps.

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 (or four red and four amber) lamps designed to conform to SAE Standard J887, July 1964 (a copy is enclosed for your information).

Previously, we were twice asked whether a school bus warning system consisting of LED strobe lights met the requirements of FMVSS No. 108. I enclose copies of our letters in response to those inquiries. You may use these previous interpretations as a guideline for determining whether your LED system could comply with FMVSS No. 108.

We assume that you wish to offer your product as original equipment on school buses. Please note, however, that FMVSS No. 108 also applies to replacement lamps, reflective devices, and associated equipment. [1] Thus, a manufacturer of both original equipment and replacement LED red and amber strobing warning lights is required to certify that the equipment meets the standards requirements.

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,

Jacqueline Glassman
Chief Counsel

Enclosures
ref:108
d.12/4/03