Interpretation ID: nht81-2.36

DATE: 06/19/81

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Bajaj Auto Ltd.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of May 25, 1981 with regard to turn signal pilot indicators on motorcycles.

You noted that the front turn signal lamps are directly in front of the operator and are fully visible. You therefore believe that a separate pilot indicator is unnecessary. You are correct. Pursuant to SAE Standard J588e Turn Signal Lamps, September 1970, incorporated by reference into Standard No. 108, no separate pilot indicator is required for Turn Signal Lamps that are "readily visible to the driver."

You have also pointed out that the motorcycle controls and displays standard, No. 123, "does not indicate the provisions and location of the Turn Signal Pilot Indicator." That is correct. Standard No. 108 and J588e establish the requirements for this item of vehicle equipment. I enclose a copy for your information.

ENC.

Date May 25, 1981

To

The Administrator National Highway Traffic Safety Administration 400, Seventh Street, S. W.,

Dear Sir,

We are manufacturing scooters which fall under the catagory of Class I Motorcycles. The scooters are provided with Turn Signal Lamps both at the front and rear. The front turn signal lamps are directly in front of the rider and are fully visible to the rider. In view of the fact that the front turn signal lamps are visible to the rider, we feel the same lamps can serve as a pilot indicator and provision of seperate pilot indicator is not necessary. Please let us know whether our contention is proper from the standards point of view.

In this connection we would like to bring to your kind attention that Standard No. 123 - Motorcycle Controls & Displays as well as the statement of compliance does not indicate the provision and location of the turn signal pilot indicator.

We are enclosing herewith the pamplet which shows the photograph of the vehicle. Thanking you

For BAJAJ AUTO LIMITED (M. S. KESHAV) MANAGER (R&D)