United States Department of TransportationInterpretation ID: 2665o
House of Representatives
Washington, D.C. 20515
Dear Mr. Wilson:
This is in response to your letter of December 9, 1987, to Ms. Brenda Brown, Office of Congressional Affairs, Department of Transportation, which has been forwarded to this Office for reply. Unfortunately, the Department has no record of receiving your previous letter of August 19, 1987.
You have written on behalf of your constituent Mr. W. P. Brandon of Palestine who has designed a "Wide Right Turn" signal for installation on the rear of trailers. The device consists of the words "Wide Right Turn" and an arrow, in black on a "caution yellow" background. The device is attached to the lower right rear of a trailer, and flashes when the turn indicator is positioned for a right turn. Mr. Brandon asks three questions with respect to his device, which I shall answer shortly.
Preliminarily let me note that the applicable Federal law and regulation are, respectively, the National Traffic and Motor Vehicle Safety Act of l966, and Federal Motor Vehicle Safety Standard No. l08 Lamps, Reflective Devices, and Associated Equipment. Standard No. l08 permits a supplementary lighting device such as Mr. Brandon's as original trailer equipment if it does not impair the effectiveness of the lighting equipment that Standard No. 108 requires, such as the standard turn signal system. The Vehicle Safety Act permits it as aftermarket trailer equipment if its installation by a person other than the trailer owner does not render inoperative, wholly or in part, equipment installed on the trailer pursuant to Standard No. l08 or any other safety standard.
With these general remarks in mind, we reach the three questions that Mr. Brandon asked.
"l. Is there any rule regarding the placement of a flashing 'Wide Right Turn' signal on the lower right rear of a trailer?"
The answer is no, as long as there is no impairment of the effectiveness of the other rear lamps (i.e., the standard turn signal must continue to operate when the lever is in the position indicating a right turn, but the wide turn signal should not operate when the hazard warning signals (which operate through the turn signal lamps) are on). "2. Can the signal be black letters on a safety yellow background or should it be another color"?
The agency does not prescribe the color of supplementary lighting devices, and color is subject only to the "impairment" restriction. Required lighting equipment on the rear of trailers may be white (back up lamps), amber (turn signals), or red (the alternative color for turn signals, and the required color for taillamps and stop lamps). I am unsure what "safety yellow" is, but it would not appear to impair the effectiveness of the red, amber, or white lamps on the trailer's rear.
"3. Are there any restrictions on manufacturing of the signal insofar as materials or construction are concerned?"
There are no Federal restrictions or requirements. However, supplementary lighting devices such as Mr. Brandon's are subject to regulation in all their aspects by the States in which they will be sold and used. We are not conversant with State regulations on this subject, and suggest that, for further advice, Mr. Brandon contact the American Association of Motor Vehicle Administrators, 120l Connecticut Ave., N.W., Washington, D.C. 20036.
We appreciate Mr. Brandon's interest in safety, and your writing us with respect to his "Wide Turn Signal" device.
Sincerely,
Erika Z. Jones Chief Counsel
ref:l08 d:2/19/88