Updated requirements for Technical Standards Document 108

Current status: Closed

Open on October 4, 2024, and will be closed on December 3, 2024.

We regulate the safety performance of motor vehicles and equipment in Canada under the Motor Vehicle Safety Act. The Act requires any company that imports or makes vehicles in one province and sells them in another province to certify that these new vehicles meet all applicable safety regulations and standards.

The Canada Motor Vehicle Safety Standard (CMVSS) 108 - Lighting System and Retroreflective Devices contains provisions for lights installed on road vehicles. The standard incorporates Technical Standards Document (TSD) 108 – Lamps, Reflective Devices, and Associated Equipment. TSD 108 sets the requirements for original lamps, reflective devices, and associated devices. TSD 108 is a reproduction of the United States’ National Highway Traffic Safety Administration’s lighting standard.

For school bus signal lamps, TSD 108 currently requires:

  • 4 mandatory red lamps (2 at the front and 2 at the rear)
  • 4 optional amber lamps (2 at the front and 2 at the rear) 

The Regulations Amending the Motor Vehicle Safety Regulations (School Buses) were published in the Canada Gazette, Part I on July 2, 2022. During the consultations for this publication, stakeholders asked us to review the allowance for optional amber warning lamps in CMVSS 108. This was because the 8-lamp warning system (a combination of red and amber warning lamps) had been adopted in all jurisdictions in the United States and Canada except for Ontario. Since publishing the Part I, Ontario now requires the 8-lamp system on school buses.

This proposal would update TSD 108 to require the 8-lamp warning system. This would make the 4 amber lamps mandatory on school buses in addition to the red lamps.

This change will support transporting students safely by improving clarity and communication to other road users when school buses are slowing and stopping.

This consultation is only addressing the changes related to mandatory amber lamps. The highlights from the June 2024 consultation to allow adaptive driving beams that comply with the United States requirements published on February 22, 2022 are highlighted in this document in a different colour. This is to show how TSD 108 would read once published.

Reference documents

Proposed TSD 108 (changes highlighted in yellow)

  • In the English version, the changes are on page 114
  • In the French version, the changes are on page 116

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How to participate 

Please email your feedback by December 3, 2024, to: RegulationsClerk-ASFB-Commisauxreglements@tc.gc.ca. Include “Update to Technical Standards Document (TSD) 108” in the subject line.

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Email: RegulationsClerk-ASFB-Commisauxreglements@tc.gc.ca