ID: 8816

Mr. Charlie McBay
Chief Engineer
Barrett Trailers, Inc.
P.O. Box 890670
Oklahoma City, OK 73189-0670

Dear Mr. McBay:

We have received your letter of June 13, 1993, asking that this Office review the two drawings you enclosed "for compliance with the upcoming conspicuity requirement", and "ask that our installation have your approval."

Under the National Traffic and Motor Vehicle Safety Act the manufacturer has the responsibility of determining whether its product conforms and then certifies its compliance with all applicable Federal motor vehicle safety standards. The Act does not provide authority for the agency to "approve" or "disapprove" any specific solution to methods of conformance. For this reason, we are unable to advise you in the manner you seek.

However, the agency does provide interpretations when specific questions are asked with respect to the requirements of the standard, and we are pleased to respond accordingly to your inquiries. You have raised four issues for our comment.

1. You have called to our attention that the "outside post" design of the trailers is configured so that the spacing of the posts along the length of the trailers is not the same. The retroreflective material will be evenly spaced in most areas, but breaks between material vary. You have asked whether this will "suffice for evenly distributed."

Under S5.7.1.4.2(a) of Federal Motor Vehicle Safety Standard No. 108, retroreflective sheeting applied to each side of a trailer need not be continuous "as long as not less than half of the length of the trailer is covered and the spaces are distributed as evenly as practicable." As we have advised many times, under Standard No. 108 the determination of practicability is to be made by the manufacturer in fulfillment of its obligation to certify that its product conforms to all applicable Federal motor vehicle safety standards. NHTSA believes that, as a general rule, a manufacturer is in the best position to determine what is practicable for its particular design. However, if that determination appears erroneous on its face, NHTSA will question it. Were you to manufacture trailers with the side conspicuity treatment spacings depicted on your drawings, NHTSA would not question your determination of practicability.

2. You have asked "if an area exists where a minimum 12" strip will not fit, can we install smaller material or must this area stay blank?"

As noted above, under S5.7.1.4.2, a strip of retroreflective material need not be continuous "as long as not less than half of the length of the trailer is covered." Therefore, if exclusion of the area in question would not result in less than half of the length of the trailer being covered, the area may be left blank.

If additional sheeting is required for a trailer to meet the length requirement, or if a manufacturer simply wishes to add it, it need not be "a minimum 12" strip." S5.7.1.3(d) of Standard No. 108 specifies that each segment of retroreflective sheeting shall have a length of 300 mm (i.e., 12 inches) +/- 150 mm. Therefore, a segment of sheeting as short in length as 150 mm (6 inches) could be applied to the area in question in compliance with the standard. An even shorter segment is permitted if necessary "to clear obstructions" if that should be the reason in your instance where a strip of 300 mm will not fit.

If the length of the area in question is smaller than 150 mm and its coverage is required for the conspicuity treatment on the trailer to meet the length requirement, then any length of material is acceptable.

3. You have asked us to note that the white strips in the upper rear corners do not meet. You have asked "Must white be touching or can there be a gap between the strips?"

Figure 30 "Typical Trailer Conspicuity Treatments" depicts two configurations in which the white strips of retroreflective material intersect at right angles in the upper rear corners. The requirement that Figure 30 illustrates is set forth in S5.7.1.4.1(b), which specifies, in pertinent part, "two pairs of white strips of sheeting, each pair . . . applied horizontally and vertically to the right and left upper contours of the body . . . as close to the top of the trailer and as far apart as practicable." There is no explicit requirement in this paragraph that the horizontal and vertical strips intersect or touch. There is an implicit requirement in the specification that the strips be "as close to the top and as far apart as practicable", but the requirement is subject to the manufacturer's determination of practicability. In other words, if the manufacturer's determination of practicability results in a gap between the strips, NHTSA will not question this determination unless it appears clearly erroneous.

4. You represent that your design makes it impossible "to make a nice continuous square corner", and that "[i]nstallation of the white corners is also closer than 3" from red top rail lights." You ask whether there is "any tolerance on the 3" dimensions?

There is no tolerance on this requirement. S5.7.1.4(b) states that "The edge of white sheeting shall not be located closer than 75 mm to the edge of the luminous lens area of any lamp that is required by this standard." The diagrams you enclose depict the horizontal white strip directly below the clearance lamps, which are required by Standard No. 108, so that each design does not accord with Standard No. 108.

We have some comments on each design. On "Model 80MP6-DD" it appears to us that, under a determination of practicability, the white strips could be lowered until the required minimum spacing between it and the clearance lamp was achieved. There is no prohibition against placing the material on the roll-up door.

The trailer identified as "GNXS-207" raises a more difficult problem because there appears to be no place where the strips could be relocated. Consideration must be given, therefore, to relocation of the clearance lamps. Under Table II of Standard No. 108, clearance lamps are intended to "indicate the overall width of the trailer". Although clearance lamps should be "as near the top . . . as practicable", they need not be "[w]hen the rear identification lamps are mounted at the extreme height of a vehicle" (S5.3.1.4). The rear identification lamps on GNXS-207 are mounted at the extreme height of the vehicle. The clearance lamps could be relocated to the fender where the stop, turn, and taillamps are presently installed. In that location, the clearance lamps would also be better able to fulfill the intent that they indicate the overall width of the trailer, which appears to occur at the fender rather than at the upper part of the body.

We hope that these interpretations are helpful.

Sincerely,

John Womack Acting Chief Counsel

ref:108 d:7/14/93

ID: 8830

Mr. Kenneth E. Ross
752 Hillpine Terrace
Atlanta, GA 30306

Dear Mr. Ross:

This responds to your letter requesting information about a product that attaches to an automobile's back window. In a telephone conversation with Marvin Shaw of my staff, you stated that your product is a two to three inch high LED sign that extends along most of the rear window. The sign displays any message that the driver chooses. While we do not have information about State or local laws, I am pleased to have this opportunity to explain the applicability of Federal law on your product.

By way of background information, NHTSA is authorized to issue Federal Motor Vehicle Safety Standards that set performance requirements for new motor vehicles and items of motor vehicle equipment. NHTSA does not, however, approve or certify any vehicles or items of equipment. Instead, the National Traffic and Motor Vehicle Safety Act ("Safety Act") establishes a "self-certification" process under which each manufacturer is responsible for certifying that its products meet all applicable Federal motor vehicle safety standards (FMVSSs).

In response to your question, NHTSA currently has no FMVSSs that directly apply to the product you wish to manufacture. I note, however, that there are other Federal requirements that indirectly affect you and your product. Under the Safety Act, your product is considered to be an item of motor vehicle equipment. As a manufacturer of motor vehicle equipment, you are subject to the requirements in 151-159 of the Safety Act concerning the recall and remedy of products with safety related defects. I have enclosed an information sheet that briefly describes those responsibilities. In the event that you or NHTSA determines that your product contains a safety- related defect, you would be responsible for notifying purchasers of the defective equipment and remedying the problem free of charge.

Automotive accessory equipment that a dealer adds before sale of a vehicle must not create a noncompliance with the FMVSSs to which the vehicle manufacturer has certified compliance. For instance, your LED sign should be mounted so that it does not block the field of view required by FMVSS No. 111, Rearview Mirrors. Similarly, for the vehicle to remain in compliance, your system must not impair the effectiveness of the lighting equipment required by FMVSS No. 108, Lamps, Reflective Devices, and Associated Equipment. In particular, the placement of your sign might impair the effectiveness of the center highmounted stop lamp (CHMSL) if it can be operated simultaneously with the CHMSL or at a time when the turn signals are flashing.

In addition, manufacturers, distributors, dealers, and motor vehicle repair businesses are subject to 108(a)(2)(A) of the Safety Act, which states: "No manufacturer, distributor, dealer, or motor vehicle repair business shall knowingly render inoperative ... any device or element of design installed on or in a motor vehicle or item of motor vehicle equipment in compliance with an applicable Federal motor vehicle safety standard ...." It is conceivable that your product, when placed on a vehicle's rear window, could "render inoperative" the vehicle's ability to comply with FMVSS No. 108 and FMVSS No. 111. Persons in the aforementioned categories that install your product must ensure that such installation does not render inoperative the safety protection provided by the applicable standards. Specifically, your product should be mounted so that it does not interfere with the CHMSL or turn signal lamps nor block the field-of-view required by FMVSS No. 111.

The "render inoperative" prohibition of 108(a)(2)(A) does not apply to the actions of vehicle owners in adding to or otherwise modifying their vehicles or items of motor vehicle equipment. Thus, if your product were placed on a rear window by the vehicle owner, then the render inoperative provision would not apply. Nevertheless, in the interest of safety, you should ensure that your product does not adversely affect a vehicle's rear lamps or rearward visibility.

We are unable to advise you as to whether the laws of any State address this topic. You should consult the American Association of Motor Vehicle Administrators for an opinion. Its address is 4600 Wilson Boulevard, Arlington, Va. 22203.

I hope you find this information helpful. If you have any other questions, please contact Marvin Shaw of my staff at this address or by phone at (202) 366-2992.

Sincerely,

John Womack Acting Chief Counsel

Enclosure ref:108#111 d:8/13/93

ID: 8832

Mr. Charles Jennings
1330 Heathwick Lane
Houston, TX 77043

Dear Mr. Jennings:

This responds to your letter received in this Office on July 2, asking for an opinion of your invention, the Alternating Wavelength Low-Beam (AWL).

The AWL "connects to the already existing low beam headlights, by just plugging it between the electrical sockets and the lights." The effect of the device is to create "light modulations of less than 17 per second, alternating from one of the two existing low-beam headlights to the other, and at the same time, changing wavelengths slightly, from one to the other (not flashing on and off)."

We have no opinion on the safety merits of your invention but can provide you with an interpretation of its relationship to Federal law. The AWL appears intended as an aftermarket device. There are no Federal restrictions on the sale of this device. Nor is there any Federal restriction upon installation of the AWL when it is installed on a vehicle by its owner. Such an installation appears a distinct possibility from your brief description of it. At this point, the question of the legality of its use is determined under the laws of the States where the AWL is operated. You represent that its operation in Texas is acceptable to the Department of Public Safety. However, this opinion would not be binding on other States. We are unable to advise you on the legality of using the AWL in the various States and suggest that you ask for an opinion from the American Association of Motor Vehicle Administrators, 4600 Wilson Boulevard, Arlington, VA 22203.

However, the National Traffic and Motor Vehicle Safety Act (the Act) prohibits most persons other than the owner (specifically, manufacturers, distributors, dealers, and motor vehicle repair businesses) from acts that may "knowingly render inoperative", in whole or in part, safety equipment that the vehicle manufacturer has added pursuant to a Federal motor vehicle safety standard. The lower-beam headlamps are original equipment installed by the vehicle manufacturer under Federal Motor Vehicle Safety Standard No. 108 Lamps, Reflective Devices, and Associated Equipment. Standard No. 108 requires headlamps to be steady-burning in use, though means may be provided to flash them on and off automatically for signalling purposes. Because the modulation created by the AWL results in a headlamp beam that is neither steady burning nor an on-off signal flash, the vehicle's headlamp system would no longer be in compliance with Standard No. 108. In our view, the headlamp system's performance would have been rendered partially inoperative within the meaning of the Act's prohibition when the AWL is sold in the aftermarket and installed by a manufacturer, distributor, dealer, and motor vehicle repair business. The Act provides for a civil penalty of up to $1,000 for each violation of the prohibition.

We hope that you find this information useful.

Sincerely,

John Womack Acting Chief Counsel

ref:108#VSA d:8/2/93

ID: 8834

Mr. Dave Beidleman
Arizona Department of Transportation
Equipment Services

FAX 602-258-5193

Dear Mr. Beidleman:

We have received your FAX of July 2, 1993, to the attention of Taylor Vinson of this Office, asking for an interpretation of Motor Vehicle Safety Standard No. 108 as it pertains to the location of rear identification lamps.

The rear configuration of l0 dump trucks that are being constructed for the Arizona DOT is such that you would like to raise the center lamp of the three-lamp identification lamp cluster approximately 1 1/2 inches; the two outer lamps of the array cannot be raised due to the positioning of the underbody tailgate release mechanism.

Table II of Standard No. 108 requires that the identification lamps be mounted "as close as practicable to the top of the vehicle, at the same height, and as close as practicable to the vertical centerline." In our opinion, the lamps in an identification lamp cluster must be equally spaced laterally and mounted at the same height in order for the identification lamp system to perform its intended purpose. Therefore, I am afraid the agency cannot accept a lamp display that differs. Although the lamps could be mounted on the rear of the cab, we understand that in that position they could be obscured by the top lip of the dump body.

We realize that the contractor has pre-punched holes for the lamps, which would be flush-mounted in the rear cross sill of the truck body. If a way were found to cover the holes, there are surface-mounted lamps available which could be mounted at the same height (your desired height for the center lamp) in a manner than should not affect the positioning of the underbody tailgate release mechanism.

Sincerely,

John Womack Acting Chief Counsel

ref:108 d:7/29/93

ID: 8836a

Mr. Howard Schecter
P. O. Box 61353
Honolulu, HI 96839

Dear Mr. Schecter:

This responds to your request for an interpretation of Federal Motor Vehicle Safety Standard No. 115, Vehicle identification number - basic requirements (49 CFR 571.115). In a telephone conversation with Dorothy Nakama of my staff, you explained that you own a three-wheel motorcycle built with all used parts. The engine and other parts are from a used Corvair passenger car, and additional parts are from used motorcycles. Your letter asks whether your motorcycle must be assigned a vehicle identification number (VIN). The answer is no.

Standard No. 115 applies to new motor vehicles, including motorcycles. NHTSA does not consider your motorcycle as new, since it was built entirely out of used parts. Since Standard No. 115 applies only to new motor vehicles, and NHTSA does not consider your motorcycle to be new, the motorcycle's rebuilder need not, under NHTSA's regulations, assign a VIN to the motorcycle.

Your letter stated that the State of Hawaii's Reconstructed Vehicle Department (RVD) would not register your motorcycle since it has no VIN. Registration procedures for motor vehicles are set by each State, not NHTSA. However, we suggest that you show this letter to the RVD officials to explain that your motorcycle need not be assigned a VIN under NHTSA's regulations.

I hope that this information is useful. If you have any further questions, please contact Dorothy Nakama at (202) 366- 2992.

Sincerely,

John Womack Acting Chief Counsel ref:115 d:8/16/93

ID: 8838

Mr. Ron Marion
Sales Engineer
Thomas Built Buses, Inc.
P.O. Box 2450
1408 Courtesy Road
High Point, N.C. 27261

Dear Mr. Marion:

This responds to your inquiry about the applicability of Standard No. 131, School Bus Pedestrian Safety Devices, to school buses you wish to sell to a customer in the United States Virgin Islands. You stated that these buses will be built as right hand drive vehicles with the entrance door located on the left side, since vehicles are driven on the left side of the road in this jurisdiction. You asked whether you can install, on the right side of the bus, the stop signal arm that is required by FMVSS 131. The answer is yes.

The National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1381, "Safety Act") requires new school buses sold in this country and in the U.S. Virgin Islands to comply with all applicable Federal school bus safety standards. (See, 15 U.S.C. 1391(8) for reference to the Virgin Islands.) Standard No. 131 requires school buses to be equipped with a stop signal arm "on the left side of the bus." (S5.4) The purpose of this standard is "to reduce deaths and injuries by minimizing the likelihood of vehicles passing a stopped school bus and striking pedestrians in the vicinity of the school bus." (S2)

When NHTSA specified that the stop arm must be placed on "the left side of the bus," the agency meant the driver's side. Comments to the notice of proposed rulemaking (NPRM) and preamble of NHTSA's final rule all assumed that the left side of the bus meant the driver's side. (56 FR 20363, 20367). For example, while endorsing the proposed requirement for the stop arm, several commenters stated that an arm is needed near the driver's window. Moreover, S5.4.1(b) states that, for locating the arm, "the top edge of the stop signal arm is parallel to and not more than 6 inches from a horizontal plane tangent to the lower edge of the frame of the passenger window immediately behind the driver's window." (Emphasis added). This provision indicates that the agency assumed that the "left" side is the driver's side. Further, a stop arm would not be needed on the non-traffic side of the vehicle.

Since the left side is not the driver's side for the school buses in question, the agency's general assumption was incorrect. In light of your letter, we will issue a technical amendment of Standard 131 so that S5.4 will require the stop signal arm on the driver's side of the bus. Until the amendment is issued, we will not take enforcement action regarding a manufacturer's locating a right hand drive school bus with a stop signal arm on the bus's driver's side.

I hope this information is helpful. If you have any questions about NHTSA's safety standards, please feel free to contact Marvin Shaw at this address or by telephone at (202) 366-2992. Sincerely,

John Womack Acting Chief Counsel

ref:131 d:8/l6/93

ID: nht88-3.91

TYPE: INTERPRETATION-NHTSA

DATE: 11/03/88 EST

FROM: ERIKA Z. JONES -- CHIEF COUNSEL, NHTSA

TO: T.P. BAILEY -- LEGISLATION ENGINEER, INTERNATIONAL AUTOMOTIVE DESIGN

TITLE: NONE

ATTACHMT: MEMO DATED 6-10-88, TO NHTSA, FROM T. BAILEY - INTERNATIONAL AUTOMOTIVE DESIGN, FMVSS 104 WINDSHIELD WIPING & WASHING SYSTEMS

TEXT: This responds to your letter of June 10, 1988, in which you asked for an interpretation of Standard NO. 104, Windshield Wiping and Washing Systems (49 CFR @571.104). More specifically, you asked two questions about the requirements set forth in section S4.1.2, Wiped area, of Standard No. 104.

You first asked whether section S4.1.2 of Standard No. 104 applies only to passenger cars. The answer to this question is yes. Section S4.1.2 reads as follows: "When tested in accordance with SAE Recommended Practice J903a, May 1966, each passenger car windshield shall . . ." (emphasis added). The underlined language explicitly limits the requirements to passenger car windshields. Hence, the windshields on other vehicle types are not subject to the requirements of S4.1.2.

Your second question involved the dimensions of "Area A" used to determine whether a car complies with the wiped area requirements in section S4.1.2. Section S4.1.2.1 of Standard No. 104 specifies that the dimensions for "Area A" are established as shown in SAE Recommended Practice J903a, may 1966, and specifies that at least 80 percent of "Area A" must be wiped. Following the procedures set forth in the SAE Recommended Practice, you noted that "Area A" on a hypothetical vehicle would extend to the day light opening area on one side of the windshield and extend beyond the daylight opening area on the other side of the windshield. When calculating the percentage of Area A that is wiped, your letter sets forth four different possible dimensions for Area A and asks which is used to determine whether the vehicle wipes at least 80 percent of Area A. Again section S4.1.2 explicitly answers this question. That section specifies that each passenger car windshield shall wipe 80 percent of Area A that "is wit hin the area bounded by a perimeter line on the glazing surface 1 inch from the daylight opening."

Please let me know if you have any further questions or need any additional information.

ID: nht88-3.92

TYPE: INTERPRETATION-NHTSA

DATE: 11/03/88 EST

FROM: ERIKA Z. JONES -- CHIEF COUNSEL, NHTSA

TO: MAX J. MIZEJEWSKI -- FOREIGN MARKETING SPECIALISTS, INC.

ATTACHMT: LETTER DATED 04-07-88 RE: ROAD READER TO NHTSA FROM MAX J. MIZEJEWSKI, FOREIGN MARKETING SPECIALISTS, INC.; OCC-1862; UNDATED LETTER TO MARK JANSEN, CHEVY DUTY PICK UP PARTS, FROM ERIKA Z. JONES, NHTSA; A32; STD.108

TEXT: This is in response to your letter in which you asked whether a product your company plans to import would be subject to any Federal motor vehicle safety standard (FMVSS). According to your letter, this product, which you refer to as a "Roadreader," att aches to the front of a motor vehicle and has two sensors which give a visual and audible alarm when the vehicle drifts off a road. You indicated that this product would be connected to the wiring related to the turn signals. You noted that this device does not affect vehicle functions such as acceleration, braking lighting, or visibility. You further stated that if required, you would provide the device to NHTSA or another government agency for inspection.

Section 103 of the National Traffic and Motor Vehicle Safety Act ("Safety Act") directs the National Highway Traffic Safety Administration (NHTSA) to establish safety standards for motor vehicles and motor vehicle equipment. Title 49 CFR Part 571 contai ns the safety standards promulgated by the agency. Although you stated that this device does not affect the electrical wiring related to the turn lights, I suggest you closely review Standard No. 108,Lamps, Reflective Devices, and Associated Equipment ( Copy enclosed). This safety standard applies to both motor vehicle equipment installed in new motor vehicles and replacement equipment sold in the aftermarket.

While I cannot conclusively say that this standard is or is not applicable to your product based on the limited facts in your letter, this standard may apply to your product because the wiring for your device is connected to components (i.e., turn lights ) subject to the standard. For instance, S4.5.11 requires that components including the turn signal lamps must be wired to flash. More generally, S4.1.3 forbids the installation of an additional piece of motor vehicle equipment that impairs the lightin g equipment required by Standard No. 108. Therefore,

a device such as yours is permissible as original vehicle equipment provided that it does not impair the effectiveness of the lighting equipment required by the standard.

As for the sale of your product in the aftermarket for vehicles in use, Section 108 of the Safety Act prohibits a manufacturer, distributor, dealer, or motor vehicle repair business from knowingly rendering inoperative any device or element of design ins talled on or in a motor vehicle or item of motor vehicle equipment in compliance with a FMVSS. Since an importer is defined by the Safety Act as a manufacturer, you should assure that installation of your device does not render inoperative, in whole or in part, the turn signal lamp or any other item of motor vehicle equipment subject to Standard No. 108.

As for your second question concerning inspection and approval of your product, you should be aware that NHTSA does not provide approvals of motor vehicles and motor vehicle equipment. Under Section 114 of the Safety Act, it is the responsibility of the manufacturer to ensure that its vehicles or equipment comply with all applicable safety standards. Further, as you noted, you would be responsible for recalling any safety-related defects which you or this agency finds in your product.

You also should be aware that laws from particular States may apply to your device. Therefore, you may wish to contact the State and local transportation authorities in the areas where you intend to market your product. The American Association of Moto r Vehicle Administrators (4600 Wilson Boulevard, Arlington, Va. 22203) may also be able to provide information about State laws concerning devices similar to your product.

Enclossssssure

ID: nht88-3.93

TYPE: INTERPRETATION-NHTSA

DATE: 11/03/88 EST

FROM: ERIKA Z. JONES -- CHIEF COUNSEL, NHTSA

TO: A. L. BRAGG -- LABORATORY MANAGER, TRUCK-LITE CO., INC.

TITLE: NONE

ATTACHMT: LETTER DATED JUNE 22, 1988 RE: REQUEST FOR INTERPRETATION OF S4.1.1.16 AND S4.1.17 IN STANDARD NUMBER 108; OCC-2303

TEXT: This is in reply to your letter of June 22, 1988, to Mr. Vinson of this Office asking for an interpretation of Motor Vehicle Safety Standard No. 108.

It is your understanding that for purposes of measuring the effective projected illuminated area of a lens, the reflex area, if any, must be subtracted from the total lens area. Your company manufactures a combination lamp which "has four square inches of reflector area and eight square inches of stop, tail and turn area." You have asked if you may advise your customers that this lamp may be used on vehicles whose overall width is 80 inches or more:

"A) Singularly (that is one on each side of the vehicle in the rear) as a stop, turn, tail and reflex reflector?

B) In combination of two's or three's (on each side of the rear of the vehicle), provided that the lamps are separated by at least twenty-two inches?"

Your understanding is correct, that the effective projected illuminated lens area must be determined without reference to any reflex reflector that may be combined with it. If the turn signal function in your lamp is met by one compartment, your lamp is acceptable under "A)." But if the turn signal function is met by more than one compartment, your lamp would not be acceptable as the area of each compartment is less than 12 square inches. With regard to "B)," the lamps could be used in combinations of twos and threes if they are mounted more than 22 inches apart but could not be used if mounted closer than 22 inches.

You also asked about the relationship to paragraph S4.1.1.7. This paragraph covers replacement equipment only, without reference to its location on a vehicle. It applies only to turn signal lamps intended to replace original equipment turn signal lamps on vehicles manufactured in accordance with SAE Standard J588d, June 1966. The current original equipment is SAE standard J588e September 1970.

You should be aware that the Truck Safety Equipment Institute has petitioned for rulemaking the effect of which would be to extend the 12-inch requirement to lamps used on all wide vehicles without reference to the 22-inch spacing. At present the agency is reviewing this petition.

I hope that this answers your questions.

ID: nht88-3.94

TYPE: INTERPRETATION-NHTSA

DATE: 11/03/88 EST

FROM: ERIKA Z. JONES -- CHIEF COUNSEL NHTSA

TO: RICHARD W. WARD -- V. P; K-D LAMP COMPANY

TITLE: NONE

ATTACHMT: LETTER DATED SEPTEMBER 14, 1988 TO ERIKA Z. JONES, NHTSA ADMIN., FROM RICHARD W. WARD, V.P., K-D LAMP CO.; OCC 2555

TEXT: This is in reply to your letter of September 14, 1988, asking for a clarification of Federal requirements for the minimum lens area for turn signal lamps and stop lamps.

The understanding expressed in your letter is correct. The SAE materials for turn signal lamps and stop lamps for wide vehicles incorporated by reference in Table I apply to original equipment on vehicles currently being manufactured, and to equipment i ntended to replace such original equipment. These standards were expressly incorporated to supersede earlier versions of SAE standards for turn signal lamps and stop lamps. However, in recognition that original equipment lamps made to earlier SAE speci fications might not be compatible with the electrical systems of vehicles designed to conform to later SAE specifications, the agency adopted paragraphs S4.1.1.6 and 4.1.1.7, allowing the continued manufacture for replacement purposes only, of turn signa l lamps and stop lamps designed to conform to earlier specifications. Both sections incorporate in their text portions of the earlier SAE standards. Because the earlier specification for turn signal lamps, J588d, required an effective projected luminou s area not less than 12 square inches for turn signal lamps on wide vehicles, this requirement is also specified in S4.1.1.7 for replacement lamps manufactured in conformance with J588d.

In short, your interpretation is correct with respect to turn signal lamps manufactured for installation on vehicles whose overall width is 80 inches or more. Single compartment turn signal lamps designed to conform to SAE J588e need meet only a minimum luminous lens area of 8 square

inches. But if a turn signal lamp is manufactured to replace a turn signal lamp that was designed to conform to SAE J588d, its minimum luminous lens area is 12 square inches.

I hope this clarifies the matter for your customer.