Interpretation ID: nht91-7.18

DATE: November 25, 1991

FROM: Don Weidman -- Manager, Special Projects, The Grote Manufacturing Company

TO: Paul Jackson Rice -- Chief Council, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 12-10-91 from Paul Jackson Rice to Don Weidman (A38; Std. 108)

TEXT:

On May 15, 1990 in the Federal Register Docket 88-17 Notice 2 a final rule was issued to become effective on December 1, 1990 requiring vehicles 80 inches or more in width to have stop and turn lamps with 75cm(2) of "effective projected luminous lens area" (EPLLA).

This occurred when NHTSA adopted SAE J-1395 April 85 for turn lamps and J-1398 May 85 for stop lamps.

Question is how will these new larger requirements affect the agriculture vehicles and implements when they are traveling on the highways?

Presently SAE J-137 June 89 covers lighting and marking of agriculture equipment on highways.

It requires a single tail light which meets J-585 and has no area requirements.

It requires at least two amber flashing warning lamps conforming to J-974. J-974 requires the lamp to have an effective projected illuminated area of 12 in(2).

Paragraph 3.14 of SAE J-137 states "when turn indicators are provided the amber flashing warning lamps shall be used as turn indicators".

What lighting and safety equipment standards must the agriculture equipment comply with to be legal when operating on the highways FMVSS-108 or SAE J-137?

If the warning lamp also serves as a turn signal lamp and the 12 in(2) effective projected illuminated lens area required in J-974 is measured by including all illuminated areas such as lens legs, and screw bosses will this be considered legal when operating on the highways?

We would appreciate knowing NHTSA's position on this issue.

We have one of our customers in the process of making a decision on their future purchases of lighting devices, therefore we would appreciate receiving your reply as soon as possible.