United States Department of TransportationInterpretation ID: 2670y
97 W. Silver Lake Road N.
Traverse City, MI 49684
Dear Mr. and Mrs. Fasel:
This is in reply to your letter of August 24, 1990, to Arthur H. Neill of this agency. You have asked for an interpretation that Federal law or regulations do not prohibit "turn signals being amber and is no way an impairment to the function of the center high mounted red stop lamp."
Federal Motor Vehicle Safety Standard No. l08, Lamps, Reflective Devices, and Associated Equipment, allows the use of amber turn signals. However, since you have enclosed a drawing of a device consisting of a center highmounted stop flanked by right and left amber turn signals, your actual question appears to be whether this device is legally acceptable under Federal law.
The "Abstract" you enclosed states that the stop function "is used in conjunction with the rear bumper signal lights", indicating that the intent of the device is to provide a supplementary turn signal to a vehicle's original turn signal system. Two different models are proposed: "One model for use with an already existing rear window light or without one." The device would be available through parts stores and mail order catalogues.
With respect to aftermarket sales of motor vehicle equipment such as yours, there is only one Federal restriction: if the equipment is installed on a vehicle by a manufacturer, distributor, dealer, or motor vehicle repair business, it must not "render inoperative, in whole or in part", any element of design, or device, installed by the vehicle's manufacturer in accordance with a Federal motor vehicle safety standard.
If a passenger car already has a center highmounted stop lamp, the model of your device that does not incorporate a center lamp (i.e., consisting only of the turn signal portion) will "straddle" it. As long as the installation of your device does not affect the performance of the existing center highmounted lamp that has been installed in accordance with Standard No. l08 (for example, such as being wired in a way that reduces the light output of the center lamp) it appears permissible.
If a vehicle was manufactured before Standard No. l08 required it to have a center lamp, it does not appear that installation of the model of your device that incorporates a center highmounted stop lamp could in any way "render inoperative" any of the other rear lighting devices required by Standard No. l08.
However, in either event, you should ensure that the size of the device is such that it does not interfere with the field of view requirements of Federal Motor Vehicle Safety Standard No. lll, Rearview Mirrors, in order that compliance with this standard may be maintained after installation of your device. I include a copy of Standard No. lll for your information.
Finally, even if your device is acceptable under the conditions I have discussed above, it must not violate the laws of any State where it is used. We are unable to advise you on State laws, but suggest that you contact the American Association of Motor Vehicle Administrators, 4600 Wilson Boulevard, Arlington, Va. 22203.
Sincerely,
Paul Jackson Rice Chief Counsel
Enclosure ref:l08 d:9/25/90