Interpretation ID: nht81-3.7
DATE: 08/12/81
FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA
TO: Bajaj Auto Limited
TITLE: FMVSS INTERPRETATION
TEXT: This is in reply to your letter of July 7, 1981 asking for an "exemption" from the requirement of paragraph S4.5.6 of Motor Vehicle Safety Standard No. 108 that an illuminated pilot indicator be provided in each vehicle equipped with a turn signal operating unit.
In your opinion, the front turn signal lamps mounted on the handlebars of certain motor scooters that you manufacture can serve as pilot indicators; if a front turn signal lamp fails to operate, the failure is readily apparent to the operator; if a left turn signal lamp fails, there is an "appreciable change in the flashing rate" of the front lamp.
We concur in your interpretation. Although S4.5.6 does require the indicator, SAE Standard J588e Turn Signal Lamps, September 1970, incorporated by reference, requires it only if turn signal lamps are not readily visible to the driver. Because the operability of both front and rear turn signal lamps on the vehicles you describe may be confirmed by the front turn signal alone, the front lamp is the functional equivalent of a turn signal indicator, and a separate indicator need not be provided.
As this is a matter of long-standing interpretation of Standard No. 108 we have no plans to amend S4.5.6 to incorporate it.
SINCERELY,
Date: 7th July 1981.
To
The Administrator, National Highway Traffic Safety Administration,
Subject: Petition for exemption from the requirements for illuminated pilot indicator (Illegible Word) to 49 CFR PARTS 571 S 108 Lamps - Reflective devices and (Illegible Word) equipment.
Dear Sir,
We are herewith making a petition in connection with the above stated reference for exemption from fitting illuminated pilot indicator. The facts concerning this are placed below for your kind consideration.
PETITION:
Federal Motor Vehicle Safety Standard No. 108, S 4.5.6 states "Each vehicle equipped with a turn signal operating unit shall also have an illuminated pilot indicator. Failure of one or more lamps to operate shall be indicated in accordance with SAE Standard J 588 (e) Turn Signal Lamps" (September 1970) except where a variable lead turn signal flasher is used on a bus, truck, multipurpose passenger vehicle etc.
According to SAE J 568 (e) "Failure of one or more lamps to operate should be indicated by a "Steady On" or "Steady Off" or by a significant change in the flashing rate of the illuminated pilot indicator". Also it states "If any signal lamp is not readily visible to the driver, ther shall be as illuminated pilot indicator to give him a clear and (Illegible Word) indication that the turn signal system is turned "ON".
Also SAE J 568 (f) (Reference SAE Hand Book 1981) states "If one right and one left turn signal is not readily visible to the driver there shall be an illuminated indicator provided to give clear and unmistakable indication that the turn signal system is (Illegible Word)."
The Motor Scooters, we are manufacturing fall under the (Illegible Word) of Class I motorcycles. The scooters are provided with turn signal lamps both at the front and the rear. The front signal lamps, one left and one right are positioned on the handle bar and are directly in front of the rider and are fully visible to the rider. In our opinion those from signal lamps themselves can serve as pilot indicators based on the following analysis:
CASE (a): When both the signal lamps on one side, say right side are working, the front right lamp is visible to the rider.
CASE (b): If any of front signal lamp is not operating, the failure of it is directly observed by the rider.
CASE (c): The failure of rear lamp to operate is indicated by a appreciable change in the flashing rate of the front lamp.
In view of this, in our opinion, the vehicle conforms to the provisions of SAE J (e) and J 568 (f) without providing an illuminated pilot indicator.
BRIEF DESCRIPTION OF THE SUBSTANCE OF ORDER
In view of the above points made we would like exemption from the requirement of illuminated pilot indicator and also an ammendment in 49 CFR PART 108 S 4.5.6 saying "If visible to the rider, (Illegible Word) front signal lamp can serve as the pilot indicator".
We are enclosing herewith photographs illustrating the location of the front signal lamps on our vehicle for your observation and kind consideration.
NAME AND ADDRESS OF THE PETITIONER:
M. S. (Illegible Word) MANAGER (RESEARCH & DEVELOPMENT)
BAJAJ AUTO LIMITED (Illegible Word)
(Illegible Word) - 411 055 INDIAN.
Thanking you, For BAJAJ AUTO LIMITED
(M. S. (Illegible Word) MANAGER ((Illegible Word))
Enclosures Omitted.