Interpretation ID: aiam2402
Product Safety Engineer
The Flxible Company
970 Pittsburgh Drive
Delaware
OH
43015;
Dear Mr. Ratz: This is in reply to your letter of September 7, 1976, to Mr. Dyson formerly of this office, requesting a confirmation that an interpretation of Motor Vehicle Safety Standard No. 108, rendered to the Southern California Rapid Transit District on August 5, 1974, is still valid, and that it can be extended to include identification lamps as well.; In our earlier letter we advised the District that the installation o wiring by a manufacturer enabling a purchaser to connect it to normally steady-burning clearance lamps, enabling them to be flashed to signal a crime in progress would not violate S4.6(b) which requires clearance lamps to be steady-burning, or S4.1.3 that prohibits installation of motor vehicle equipment which impairs the effectiveness of the lighting equipment required by Standard No. 108. This will confirm that that interpretation is still valid.; Your letter, however, raises two additional issues which deserve to b answered for the record. The first is whether the bus manufacturer rather than the purchaser may make the connection, and the second is whether identification lamps may also be included in the warning system. Since it is our opinion that use of the clearance lamps in an emergency mode creates an item of lighting equipment not required by Standard No. 108 and hence outside its coverage, we have concluded that the manufacturer may connect both clearance and identification lamps to the emergency circuit without any resultant nonconformances with S4.6(b) and S4.1.3.; I hope this is responsive to your request. Sincerely, Frank A. Berndt, Acting Chief Counsel