Interpretation ID: nht75-2.49

DATE: 09/05/75

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Superindendent of Public Instruction, State Of Washington

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of July 15, 1975, to Mr. J. E. Leysath of this agency asking whether the State of Washington's proposed school bus light warning system conflicts with S4.1.4(b)(ii) of Federal Motor Vehicle Safety Standard No. 108.

That section requires an eight lamp signal system to be wired "so that the amber signal lamps are activated only by manual or foot operation, and if activated, are automatically deactivated and red signal lamps automatically activated when the bus entrance door is opened." Under the system Washington proposes, when a school bus stops, a "stop paddle sign" is extended by the operator, activating "a switching system which will terminate the yellow flashing lights and start the red flashing lights," before the door is opened.

Under the system you describe, the termination of the yellow lamps and activation of the red ones is dependent upon the operator extending the stop paddle sign. Should the operator forget to extend the sign, it does not appear that the system required by S4.1.4 would operate automatically when the door is opened. We therefore conclude that in order to meet S4.1.4 your school buses must be equipped with an override switch that would deactivate the amber lamps and activate the red ones when the door is opened, in the event that the stop paddle sign has not been extended.

Sincerely,

ATTACH.

July 15, 1975

J. E. Leyseth -- Motor Vehicle Programs, NHTSA N41-31, Department of Transportation

Dear Mr. Leyseth:

The Transportation, Traffic and Safety Division of the Office of Superintendent of Public Instruction, State of Washington, has a problem concerning the use of an eight light warning system on school buses that requires some help or an interpretation from you. We had thought our problem was connected with Standard 17, but after contacting Dave Soule we learned from him that we need to contact you instead. Mr. Soule did indicate that our proposed system is not in conflict with Standard 17, but would be in conflict with Standard 108, S4.1.4 without an exception from you.

The State of Washington has for many years required their school buses to be equipped with a four light (red) warning system for use in loading and unloading school bus passengers. Motorists are required by law to stop and hold until the students are loaded or unloaded and the warning system is deactivated. In conjunction with the light system, the State has also required for many years the use of a "stop paddle sign" on the side of the bus. The red light warning system is activated and deactivated with the use of the stop paddle sign.

The Office of the Superintendent of Public Instruction is currently engaged in activities to have the Washington State Legislature revise existing laws to permit the use of the eight light system. The proposal calls for the use procedure to be as follows: at a predetermined time or distance the driver will activate the yellow warning lights with a manual hand or foot switch. When the bus has stopped the driver will extend the stop paddle sign, which also has two flashing red lights mounted to it. The stop paddle sign, when extended, will activate a switching system which will terminate the yellow flashing lights and start the red flashing lights. When the stop paddle sign is retracted all flashing lights in the warning system are deactivated and the system is ready for the next cycle.

Two additional functions would be required. There must be a switch available to the driver to cancel the yellow warning lights once they have been started in the event that the paddle sign need not be used. The second requirement would be that the red flashing lights must activate when the paddle sign is extended, regardless of whether or not the yellow flashing lights are used.

This proposal conflicts with Standard 108, S4.1.4., (ii), which states that " . . . . the red signal lamps automatically activate when the bus entrance door is opened."

This State has not used the entrance door function in the warning light system for two reasons. Most importantly we wanted the driver to be able to engage the warning and traffic control system, make sure that traffic will indeed stop, before opening the door for students to load or unload. This provides a greater element of safety for the students. The loading cycle is also involved because we try to train students waiting for a bus on the opposite side of a street to hold and not cross the street or highway until the door is opened. This provides the driver with a signaling device to indicate to the students when it is safe to cross, and for them not to begin crossing when the paddle sign goes out or the red flashing lights come on.

The second reason is that many buses in the State of Washington are equipped with air powered entrance doors. Manual doors could possibly allow the driver to accomplish the above, but units with air doors could not accomplish the above procedure.

For the reasons stated this Office is hopeful that our proposed system is substantially in compliance with the spirit of Standard 108, and that an exception or variance could be granted to the State of Washington so that it may implement a system which will allow the stop paddle sign to activate the red flashing warning lights in the eight light system.

My office will be anxious to hear from you or to provide any further information that may be helpful to you on this request.

Thank you for your interest and consideration.

Sincerely, Superintendent of Public Instruction;

Jerry Toner, Consultant, Transportation, Traffic & Safety