Vice President of Engineering
American Trucking Associations
2200 Mill Road
Alexandria, VA 22314-4677
Dear Mr. Strawhorn:
This letter responds to your request for an interpretation of the antilock malfunction indicator requirements set forth at S184.108.40.206 of Standard No. 121, Air Brake Systems. This provision explains the situations in which the trailer lamp malfunction indicator must remain activated. Section S220.127.116.11 reads as follows:
S18.104.22.168 Antilock Malfunction Indicator. Each trailer (including a trailer converter dolly) manufactured on or after March 1, 1998 and before March 1, 2006 shall be equipped with a lamp indicating a malfunction of a trailer's antilock brake system. Such a lamp shall remain activated as long as the malfunction exists whenever the power is supplied to the antilock brake system. The display shall be visible within the driver's forward field of view through the rearview mirror(s), and shall be visible once the malfunction is present and power is provided to the system. (Emphasis added.).
In particular, you request that the agency confirm your belief that the lamp activation pattern for trailers may be such that the bulb be ON when the antilock system is working properly and OFF when a malfunction exists, the antilock system is not getting electrical power, or the lamp bulb is burnt out. You contended that such an activation pattern provides a fail safe pattern i.e., it will signal an inoperative antilock system even when the system is not receiving electrical power or the lamp bulb is burnt out.
NHTSA disagrees with your suggested reading of the malfunction indicator requirements. Such a reading would be inconsistent with S22.214.171.124's language stating that the lamp must "remain activated as long as the malfunction exists whenever the power is supplied to the antilock brake system." As with other malfunction indicators, the agency intends the malfunction indicator to activate when a malfunction exists and not activate when the system is functioning properly. To require otherwise would be inconsistent with our requirements for other indicators and thus would create confusion. Please note that NHTSA provided a lengthy discussion about the issue of a malfunction indicator's activation protocol in the March 10, 1995 final rule. (60 FR 13216, 13246) The agency stated that in response to an ABS malfunction, a trailer or tractor indicator
must activate and provide a continuous yellow signal. The agency explained that such a common indicator pattern standardizes the activation format, thus reducing ambiguity and confusion and expediting Federal and State inspections.
I hope this information has been helpful. If you have any other questions, please contact Marvin Shaw of my staff at this address or by phone at (202) 366-2992.
John Womack Acting Chief Counsel