Interpretation ID: 1983-3.2

TYPE: INTERPRETATION-NHTSA

DATE: 09/02/83

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Peterson Manufacturing Company -- Paul Scully, Vice President

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. Paul Scully Vice President Peterson Manufacturing Company 4200 East 135th Street Grandview, MO 64030

Dear Mr. Scully:

This is in reply to your letter of July 22, 1983, to Mr. Cavey of this agency.

With respect to paragraph S4.1.1.7 of Standard No.108 Lamps Reflective Devices, and Associated Equipment you have stated your understanding that paragraph applies only to turn signal lamps manufactured between January 1, 1972 and September 1, 1978, and that turn signal lamps must now comply with SAE Standard J588e, September 1970.

Paragraph S.4.1.1.7 did allow vehicular compliance with SAE J588d as an option to J588e. J588d required that any turn signal lamp used on a vehicle whose overall width was 80 inches or more have a minimum of 12 square inches effective projected luminous lens area. On the other hand, SAE J588e requires a minimum of 8 square inches effective projected luminous lens area on all single compartment rear turn signal lamps, regardless of vehicle width. However, on vehicles 80 inches or more in overall width, two turn signal lamps or compartments per side may be mounted closer together than 22 inches provided each meets single compartment photometric requirements and each has a minimum effective projected luminous lens area of 12 square inches. Thus, your understanding is correct.

I would also point out that, pursuant to Section S4.7.1 of Standard No. 108, the continued manufacture of turn signal lamps meeting J588d is permissible as replacement equipment for vehicles manufactured between January 1, 1972 and September 1, 1978.

Mr. Cavey has provided the copy of BMCS regulations which is enclosed.

Sincerely, Frank Berndt Chief Counsel

Enclosure

July 22, 1983

Mr. Kevin Cavey National Highway Traffic Safety Administration 400 Seventh Street SW Nassif Building Washington, DC 20590

Dear Kevin:

I need a copy of the Bureau of Motor Carrier Safety Regulations and I no longer have in my files the address of that agency. Would you be kind enough to telephone them and request that a copy of that booklet be forwarded to me. I would certainly appreciate it.

On a completely separate subject, a question arose today concerning the meaning of Paragraph S4.1.1.7 in FMVSS 108. The specific question related to the square inches of area needed for a turn signal on vehicles over 80".

My interpretation of the regulation has been that turn signal lamps for vehicles over 80" must comply with J588e dated September, 1970. This standard requires 8 square inches of area for single compartment lamps. That standard also spells out that when lamps are mounted closer together than 22" on vehicles over 80", they must then individually meet all of the requirements and must be 12 square inches.

Paragraph S4.1.1.7 only applies to turn signal lamps manufactured between January 1, 1972 and September 1, 1978 and simply permitted compliance with the prior standard J588d. This specific paragraph, in my judgment, only relates to vehicles built between the dates spelled out above and does not impact the area requirements as otherwise spelled out in J588e. Specifically, it is our understanding that the rear turn signal area for single compartment lamps is eight square inches regardless of the width of the vehicle. The only exception to this requirement is spelled out in the SAE standard which states that the area must be 12 square inches if indeed the units are placed closer together than 22". Can you please advise me if my interpretation is correct?

Very truly yours,

Paul Scully Vice President

PS/sld