The retrofit law, known as SB109 and now officially California vehicle code 378, affects stretch limousines carrying 10 or fewer passengers.

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Operators across California may soon be getting visits from California Highway Patrol inspectors who will remind them that stretch limousines must comply with the state’s long-awaited limo retrofit law, effective Jan. 1, 2018.

One company already has been visited and reminded, and the CHP has trained its staff on the details of the law and how to enforce it.

The retrofit law, known as SB109 and now officially California Vehicle code 378, affects stretch limousines carrying 10 or fewer passengers.

• If a stretch limousine has a fifth door, it needs either two pop-out window emergency exits OR a rooftop escape hatch.

• If a stretch limousine does not have a fifth door, then it needs two pop-out window emergency exits AND a rooftop escape hatch.

The CHP's modified limo inspection sheet requires that pop-out windows, also referred to as push-out, must be installed by an independent engineering firm or the manufacturer, and must be certified according to Federal Motor Vehicle Safety Standards (FMVSS). The sheet also lists specific minimum window dimensions.

The official language on what vehicles qualify:

378. (a) Limousine means any sedan or sport utility vehicle, of either standard or extended length, with a seating capacity of not more than 10 passengers including the driver, used in the transportation of passengers for hire on a prearranged basis within this state. 
(b) Modified limousine means any vehicle that has been modified, altered, or extended in a manner that increases the overall wheelbase of the vehicle, exceeding the original equipment manufacturer s published wheelbase dimension for the base model and year of the vehicle, in any amount sufficient to accommodate additional passengers with a seating capacity of not more than 10 passengers including the driver, and is used in the transportation of passengers for hire. For purposes of this subdivision, wheelbase means the longitudinal distance between the vertical centerlines of the front and rear wheels.

Gov. Jerry Brown signed SB109 on Oct. 11, 2013 to take effect on Jan. 1, 2015. Since then, the Greater California Livery Association succeeded several times in getting the enforcement date delayed until Jan. 1, 2018, arguing operators and coachbuilders needed time to figure out how to do the retrofits. GCLA President David Kinney ruled out the possibility of anymore extensions to the enforcement deadline. “The last time I testified, they told me not to ask for an extension.”

The retrofit law came in response to a horrific stretch limousine fire on May 4, 2013 on the San Mateo Bridge near San Francisco, in which five women celebrating a bachelorette party died when they could not escape the 1999 Lincoln Town Car 120-in. stretch. Four other women got out and survived.

A state investigation determined the fire was caused by an obscure series of catastrophic factors that so far have not been identified as causes in any other stretch limousine fires or accidents. The limousine also was carrying one passenger beyond its legal safety limit (in the limo compartment), and the chauffeur failed to immediately pull over when hearing the first warning of smoke from a passenger.

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 80-85% of California operators have never received a terminal inspection from the CHP. With this law going into effect, it will be a first for inspectors and operators, especially those with smaller fleets that have traditional stretch sedan limousines. “Now all those people will have CHP officers knock on their doors.”

That could lead to some misinterpretations or misunderstandings until enforcers get used to the law. The code also contains some vague language on some of the details,

We advises operators to ensure they have all of their legal and regulatory paperwork in order, including insurance, workers’ comp, drug-pull program records, and any fleet-related maintenance and inspection records.

And a letter of compliance are available to retrofits. Estimates vary, but a retrofit involving windows and roof hatches can range from $1,800.00 to $10,000 depending on the scope of the work.