Critical Inspection Item List

The CVSA critical inspection item list includes: Lighting Devices (Headlamps, Tail Lamps, Stop Lamps, Turn Signals and Lamps/Flags on Projecting Loads). The question is does stop lamps include high center mount brake lamps. After doing a quick jurisdictional scan in Canada, there are some jurisdictions that have regulations requiring vehicles to be installed with high center mount brake lamps and that they must be maintained and operational. Because these can be defined in regulation as a brake lamp, there is a question whether they should be considered brake lamps and therefore be considered when determining critical violations and OOS. The OOSC states that a vehicle can be placed OOS if it does not have at least one operative stop lamp on the rear of a single unit vehicle or the rear of the rearmost vehicle of a combination of vehicles visible at 500 feet. If a high center mount brake lamp were to be considered a critical inspection item (brake lamp) and is operational when the two other brake lamps, required by regulation, are inoperative would this prevent the vehicle from being placed OOS? In cases where you have a pick up truck with the high center mount brake lamp in mounted on the back of the cab maybe not because it is not at the rear of the vehicle but there are commercial vehicles such as motorcoaches, vans, pick up trucks with toppers, highway tanks, etc. that would have the high center mount brake lamp at the rear of the vehicle. Would a high center mount brake lamp that is obscured by a load be considered a critical inspection item violation because it can't be seen to the rear?

Currently there seems to be no direction on high center mount brake lamps and whether to consider those a critical inspection item. The critical inspection item list does not specifically mention high center mount brake lamps or does it specifically exempt high center mount brake lamps from the critical inspection item list.

If the intention is to not include high center mount brake lamps as a critical inspection item then additional wording should be added to the critical inspection item list and heading in the CVSA OOSC as follows: Lighting Devices (Headlamps, Tail Lamps, Stop Lamps (not including high center mount brake lamps), turn signals and Lamps/Flags on Projecting Loads. If the intention is to include high center mount brake lamps as a critical inspection item it would be nice to include some guidance in operational policy 15. Especially when it comes to placing or not placing a vehicle OOS. If the high center mount brake lamp is considered a critical item but was not intended to replace the two brake lamps at the rear of the vehicle when they are not operational then that should be specified so the OOSC is applied uniformly.