Interpretation ID: 21111.ztv

Mr. Tadzio Suzuki
Manager
Automotive Equipment
Regulation & Homologation Sect.
Stanley Electric Co., Ltd.
2-9-13, Nakameguro, Meguro-ku
Tokyo 153-8636
Japan

Re: Motorcycle turn signal lamps

Dear Mr. Suzuki:

This is in reply to your letter of December 17, 1999, asking whether a turn signal lamp design is in accordance with Federal Motor Vehicle Safety Standard No. 108. The turn signal lamp system consists of two lamps and is intended for use on motorcycles.

In Stanley's design, the turn signal lamp contains two filaments, one performing the turn function and the other functioning as a "parking lamp." The parking lamp meets the requirements of Standard No. 108. You later describe the parking lamp as "operating continuously." When the turn signal is activated, the parking lamp function is turned off in the turn signal lamp, while it continues to function in the other turn signal lamp. In your opinion,

"such electrical connection would not be accepted if it were intended for motor vehicles as specified in S5.5.10(d) - All other lamps shall be wired to be steady burning." However, FMVSS No. 108 has no specification for motorcycle ' parking lamps,' nor their electrical connection. And we believe such electrical connection does not violate the Federal Regulations.

We regard the Stanley turn signal lamp design as incorporating an auxiliary function not required by Standard No. 108 for motorcycles. Under S5.1.3, this is acceptable if it does not impair the effectiveness of the required lighting equipment. We do not believe that the "parking" system you describe would have an impairing effect, and conclude that it is permissible under Standard No. 108.

Sincerely,
Frank Seales, Jr.
Chief Counsel
ref:108
d.3/30/00