Interpretation ID: aiam2257
Esq.
1700 Pennsylvania Ave.
N.W.
Washington
DC
20006;
>>> Re: Yankee Metal Products Corporation<<< Dear Mr. Heffron: This is in reply to the petition of March 16, 1976, by your clien Yankee Metal Products Corporation ('Yankee' herein) for an interpretation of 49 CFR 571.108, Motor Vehicle Safety Standard No. 108. Yankee seeks an interpretation 'that the use of strobe type signal warning lamps on school buses is permissible provided that such lamps meet the specific performance requirements in S4.1.4 which incorporates SAE Standard J887.'; Yankee has submitted a test report by Electrical Testing Laboratories Inc. indicating conformance to SAE Standard J887 including its photometric requirements. Yankee has also submitted an opinion by a professional engineer that 'the Yankee strobe lights tested by ETL meet the photometric requirements of SAE J887.'; As you know, this agency does not 'approve' specific lighting device prior to their introduction into interstate commerce, and all that is legally required is that the manufacturer certify that its product meets all applicable Federal motor vehicle safety standards. The ETL report and professional opinion indicate that the design of the Yankee system complies with SAE J887, and thus they provide a basis upon which Yankee could certify that its system meets Standard No. 108. Therefore the use of its strobe type signal warning lamps appears to be permissible under Standard No. 108.; This means that the interpretation provided Mr. John J. Giesguth o December 9, 1975, does not apply to any strobe light system where an equivalency of conforming performance can be demonstrated, as Yankee appears to have done.; Sincerely, Frank A. Berndt, Acting Chief Counsel