Interpretation ID: nht80-2.30

DATE: 05/06/80

FROM: AUTHOR UNAVILABLE F. Berndt; NHTSA

TO: Blue Bird Body Company

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of April 14, 1980, asking for a confirmation of your interpretation of Section S4.1.4 of Motor Vehicle Safety Standard No. 108.

This section specifies requirements affecting school bus signal lamps "when the bus entrance door is opened." Blue Bird is designing an additional entrance door for its buses and you interpret S4.1.4 as requiring the same operational characteristics for the new door.

We confirm your interpretation that "entrance door" means any entrance door on the school bus. Obviously the purpose of the requirement is not achieved if it is restricted to the traditional entrance door on the right front side of the bus and excludes any other entrance door.

Thank you for your interest in safety.

SINCERELY,

BLUE BIRD BODY COMPANY

April 14, 1980

Frank Berndt Chief Counsel NHTSA

Dear Mr. Berndt:

SUBJECT: FMVSS 108

Blue Bird Body Company is in the process of designing an entrance door that will be located behind the driver on the left side of school buses. This entrance door will be in addition to the normal right front entrance door and will operate independently.

FMVSS 108 - Lamps, Reflective Devices, and Associated Equipment - Passenger Cars, Multipurpose Passenger Vehicles, Trucks, Buses, Trailers, and Motor-cycles, Section S4.1.4 requires school buses to be equipped with signal lamps that, in addition to other requirements:

"The system shall be wired so that the amber signal lamps are activated only by manual or foot operation, and if activated, are automatically deactivated and the red signal lamps automatically activated when the bus entrance door is opened."

From this statement, we interpret "entrance door" to mean any and all entrance doors. In the case described above, we interpret the standard as requiring the same operational characteristics of both the normal right front entrance door and the new left side entrance with regard to activation and deactivation of signal lamps. This letter seeks confirmation of this interpretation. Your early response will be apprecated.

Thank you!

Thomas D. Turner Supervisor Engineering Services Department

c: WILBUR RUMPH; JIM MOORMAN; BILL PIERCE