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Interpretation ID: aiam0481

Mr. K. L. Young, Specifications Analyst, The Flxible Company, Loudonville, OH, 44842; Mr. K. L. Young
Specifications Analyst
The Flxible Company
Loudonville
OH
44842;

Dear Mr. Young: This is in reply to your letter of October 22 asking whether th 'hoodlum warning system' requested by the city of Boston (MBTA) would conform to Federal Motor Vehicle Standard No. 108, *Lamps, Reflective Devices, and Associated Equipment*.; Paragraph S3.5 of Standard No. 108 permits 'normally steadily-burnin lights [to] be capable of being individually flashed for signalling purposes' on motor vehicles manufactured before January 1, 1972. Therefore the hoodlum warning system is currently permissible under Standard No. 108.; However, a new requirement effective January 1, 1972, would prohibi the installation of this system on vehicles manufactured on or after this date. Paragraph S4.6 of Standard No. 108 states:; >>>'Where activated (a) Turn signal lamps, hazard warning signal lamps, and school bu warning lamps shall flash,; (b) *All other lamps shall be steady-burning* except that means may b provided to flash headlamps and side marker lamps for signalling purposes.' (emphasis added)<<<; Sincerely, Lawrence R. Schneider, Chief Counsel