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Interpretation ID: nht94-6.44

DATE: April 8, 1994

FROM: John Womack -- Acting Chief Counsel, NHTSA

TO: Thomas Turner -- Manager, Engineering Services, Blue Bird Body Company (Fort Valley, GA)

TITLE: None

ATTACHMT: Attached to letter dated 2/15/94 from Thomas D. Turner to George Entwistle (OCC 9696); Also attached to letter dated 1/26/83 from Frank Berndt to Thomas D. Turner

TEXT:

This responds to your letter to NHTSA's Office of Safety Compliance requesting an interpretation of the conspicuity requirements in Standard No. 131, School Bus Pedestrian Safety Devices. This letter confirms your understanding that a reflectorized stop signal arm that fully complies with the reflectorization requirements in S5.3.1 complies with S5.3, regardless of whether a stop signal arm is equipped with strobe lights that do not comply with S5.3.2.

As you are aware, S5.3 conspicuity states "The stop signal arm shall comply with either S5.3.1 or S5.3.2, or both." Section S5.3.1 sets forth requirements addressing reflectorization, and S5.3.2, which references S6.2, sets forth requirements addressing flashing lamps. Section S6.2.2 specifies a stop signal arm's flash rate.

You explained that some of the stop signal arms that you install fully comply with the reflectorization requirements in S5.3.1. However, these stop signal arms are also equipped with strobe lights that do not comply with S5.3.2 because they do not comply with the flash rate requirements in S6.2.2.

As we noted above, compliance with the conspicuity requirements in S5.3 can be established EITHER by complying with the reflectorization requirements in S5.3.1 OR the flashing light requirements in S5.3.2. (emphasis added) Since the stop signal arms in question comply with the reflectorization requirements, they comply with the conspicuity requirements and need not comply with the flashing light requirements.

I hope this information is helpful. If you have any questions about NHTSA's safety standards, please feel free to contact Marvin Shaw at this address or by telephone at (202) 366-2992.