Interpretation ID: aiam3365
President
Coded Electronics Corporation
1239 Taylor
San Francisco
CA 94108;
Dear Mr. Belcher: This is in reply to your letter of August 20, 1980 asking whether you emergency hazard signaling system conforms with Federal Motor Vehicle Safety Standard No. 108. You also asked as to the steps necessary to make it mandatory.; From the specifications provided in your letter, it appears that bot modes of operation (hazard and distress) would comply with the flash rates and the percent of current 'on' time required by SAE J945, the standard for hazard warning signal flashers incorporated by reference in Standard No. 108. If your device meets all other requirements of SAE J945 and SAE J910, the standard for hazard warning signal operating units also incorporated by reference, it should comply with Standard No. 108.; I am enclosing a copy of 49 CFR Part 552, setting forth the procedure under which you may petition for an amendment of Standard No. 108 that would require a distress signaling system on vehicles.; Sincerely, Frank Berndt, Chief Counsel