Interpretation ID: nht80-1.34

DATE: 03/18/80

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: G. Mack Industries, Ltd.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of February 18, 1980, asking about the legality in the United States of a lamp with the words "DON'T PASS" which you are presently manufacturing for school buses in Canada. The lamp is intended for mounting on both the front and rear of the bus.

Such a lamp is not required in this country under Federal law. Its use as original equipment on U.S. school buses would not be prohibited by Federal Motor Vehicle Safety Standard No. 108, Lamps, Reflective Devices and Associated Equipment, since its installation would not appear to impair the effectiveness of required lighting equipment. Its legality would be determined by that of the State in which the bus is registered and operated, and therefore, you should contact the individual State for their opinion in this matter.

SINCERELY,

G. MACK INDUSTRIES LTD.

February 18, 1980

Frank Berndt, Chief Counsel National Highway Traffic Safety Administration, U.S. Department of Transportation,

Dear Sir:

In a letter I received from Mr. David Soule he suggested that I write you directly as to finding out the legality of our "DON'T PASS" light, we are presently manufacturing for the school buses in Canada.

The "DON'T PASS" light features consist of one or two flashing thirty-five candlepower seal beam units or six thirty two candlepower bulbs. The base is made out of A.B.S. a hard tough space age material that is weather resistant, and is suited for outdoor applications. The lens is made out of san and is a chemical scratch resistant plastic. Dimensions are 10" x5" x2" with a simple six screw molding which will adapt to any school bus. As to the electrical hook up we are presently using the four way flashing switch.

Enclosed is a picture and a newspaper clipping as to our headway we have made in Canada.

Appreciating your valued opinion in your early reply as to our position in the United States. I remain,

J. Leftrook Jr. President

ENC.

The Big Safety Lamp has been included in the Manitoba school bus specifications and the Manitoba Highway Traffic Act has been amended to give approval of the light. It is now in use in all of the 52 Manitoba school divisions. Application to have the lamp made standard equipment will go before the next meeting of the Canadian Standards Association.

The lamp which is produced for the company by Melet Plastic Ltd., 670 Golspie Street, Winnipeg, is injection moulded on custom made steel dies. The lens is made of SAN, a scratch and chemical resistant plastic, and the back of the unit is made of ABS, a hard, tough, space age material that is weather resistant and specially suited to outdoor applications.

Gerry Leftrook is optimistic about the future. Negotiations are underway to have the light standardized in the United States as well as Canada. It is estimated that there are some 25,000 school buses operating in Canada and 348,000 in the United States. Production of new buses has been projected at about 7,000 per year in Canada and 35,000 per year in the United States over the next five years.

The light can be adapted to transport trailers and trucks, house trailers and campers, all of which provide a wide market potential.

(Graphics omitted)