Interpretation ID: nht71-2.22

DATE: 03/29/71

FROM: AUTHOR UNAVAILABLE; L. R. Schneider; NHTSA

TO: Volkswagen of America, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: RE: PETITION TO AMEND STANDARD NO. 103

This is in response to your petition of February 24 to Douglas Toms for a amendment of Federal Motor Vehicle Safety Standard No. 108, Lamps, Reflective Devices, and Associated Equipment (35 F.R. 16640).

You petitioned for an amendment of S4.6(b) that would allow use of a non-automatic means for flashing headlamps. Standard No. 103 does not contain requirements for, or prohibitions against, flashing headlamps non-automatically, and therefore installation of such devices is at the option of the manufacturer.

You commented that S4.6(b) appears to require simultaneous flashing of headlamps and side marker lamps if an automatic means of flashing is provided. Your interpretation is incorrect; either headlamps or side marker lamps, or both, may be flashed by automatic means.

You also petitioned for an amendment of S4.1.1.6 and S4.1.1.7 on the basis of a conflict in the dates of applicability of the effective date of the sections. Your petition on this point is moot; this ambiquity was resolved is an amendment to Standard No. 108 published on February 3, 1971 (36 F.R. 1896). I enclose a copy for your information.