Interpretation ID: nht69-2.36

DATE: 12/23/69

FROM: AUTHOR UNAVAILABLE; C. A. Baker; NHTSA

TO: Blue Bird Body Company

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of December 9, 1969, providing additional information on the school bus lighting system as described in your previous letter of November 14, 1969.

Paragraph S3.1.2 of Federal Motor Vehicle Safety Standard No. 108 specifies that, The additional lamp, reflective device, and associated equipment shall be installed if it impairs the effectiveness of the required equipment." The system of front stop lamps as described in your letters, i.e., two non-flashing amber lamps of the same size as and located in line with the two red school bus signal lamps, and actuated by the foot brake only, would not appear to impair the effectiveness of the lighting equipment required by Standard No. 108. It should be noted, however, that, while incorporation of this system in school buses would not be precluded by Standard No. 108, the various States may interpose restrictions as to such system. I would suggest, therefore, that you review the applicable State regulations before initiating installation of the system.