Interpretation ID: nht90-2.12

TYPE: Interpretation-NHTSA

DATE: April 9, 1990

FROM: Stephen P. Wood -- Acting Chief Counsel., NHTSA

TO: Patrick S. Baran -- I.D.E.A.

TITLE: None

ATTACHMT: Attached to letter dated 11-21-89 To Taylor Vinson and From Patrick S. Baran; Also attached to letter dated 8-2-82 To William R. Harris, Jr. and From Frank Berndt; Attachment SAEJ586c not included.

TEXT:

This is in reply to your letter to Taylor Vinson of this office, with respect to "D.O.T. guidelines for tail light brightness" with respect to a "brake light for the back of a motor cycle helmet. I regret the delay in responding.

The Department has no authority to "approve" or "disapprove items of equipment, but we can provide guidance on the relationship of equipment to the Federal motor vehicle safety standards. I enclose a copy of a 1982 interpretation with respect to a simila r device, a headlamp intended for installation on a motorcycle helmet. It also represents our views with respect to your device. I enclose also a copy of SAE Standard J586c Stop Lamps, which our Rulemaking office promised you.

We note that you use the term "tail light" and "brake light" interchangeably. In seeking State guidance you should be clear as to whether your device indicates the presence of the cyclist (taillamp), or the application of the brakes of the motorcycle (st op lamp), or both.