Interpretation ID: nht74-3.6

DATE: 01/15/74

FROM: W.G. MILBY -- BLUE BIRD BODY COMPANY

TO: RICHARD DYSON -- NHTSA ASSISTANT CHIEF COUNSEL

TITLE: FMVSS 108

ATTACHMT: ATTACHED TO LETTER DATED 02/19/74 FROM RICHARD DYSON TO W.G. MILBY; N40-30 [ZTV], STANDARD 108; REDBOOK (-)

TEXT: We need a ruling on whether it is legal to use rear stop lights on a bus as follows:

1. When brakes are applied rear stop lights are steady burning under all conditions.

2. Place gearshift in reverse - two backup lights are energized and the two seven inch and two four inch rear stop lights flash at a frequency between 60 and 120 cycles per minute.

The purpose for such a system is to give school pupils and others additional warning in addition to the backup lights when the bus is in reverse gear and would not interfere with the stop light function. Thanks for an early reply.

Yours very truly,