Interpretation ID: nht80-3.11
DATE: 06/25/80
FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA
TO: Vetter Corporation
TITLE: FMVSS INTERPRETATION
TEXT: This is in reply to your letter of May 28, 1980, with respect to your proposals for lighting requirements for a motorcycle sidecar currently under development. Your letter does not state so, but you indicated in your telephone conversation with Mr. Vinson of this office that the sidecar is detachable.
It has been the position of this agency that a detachable sidecar is an item of motor vehicle equipment to which no Federal motor vehicle safety standards apply. Conformance of the motorcycle therefore is judged without the sidecar attached. Therefore, the front turn signal configuration in Figure F2 would appear to meet Standard No. 108 but the asymmetrical one in Figures F1 and F3 would not. Similarly, the rear turn signal and stop lamp configurations in Figure R2 appear to comply, but those of Figures R1 and R3 do not. The configuration of Figure R4 is not prohibited by S4.1.2 since it does not appear to impair the effectiveness of the required lighting equipment. As for Figure R5, the reflective material required by the standard must be on the motorcycle itself and its appearance solely on the sidecar, as indicated on your drawing, is improper. Finally, your Figure S1 depicts front and rear reflex reflectors mounted on the right side of the sidecar. This is not acceptable as a substitute for the required front and rear reflectors on the right side of the motor as you indicate but we believe it would enhance safety if you incorporated this idea into production.
If you have any further questions, please let us know.
SINCERELY,
Vetter Corporation
May 28, 1980
Frank Berndt NHTSA Dept. of Transportation
Dear Frank:
Per a phone conversation with Taylor Vincent on May 19, 1980, we are enclosing our proposals for lighting requirements for a motorcycle sidecar currently under development.
The drawings are numbered in our order of preference. Listed below are explanations of each lighting arrangement. We would like specific information as to which proposals are acceptable. Please note that a complete view of the lighting proposal consists of front, back, and side views (F1, R1, S1).
FRONT VIEWS
Figure F1 (First Choice):
Standard left turnsignal/running light on motorcycle. Amber turnsignal/running light on sidecar. (NOTE: The motorcycle may or may not have a running light function in its turnsignal assembly. If not, the sidecar would not have a running light.)
Also, note the difference in the horizontal position of the turnsignals. (The left turnsignal is located on the left side of the fairing - see side view on F1).
The motorcycle's right turnsignal would remain attached but would be electrically disconnected.
Figure F2 (2nd Choice):
Standard right and left turnsignal/running lights on the motorcycle. No front lights on sidecar.
Figure F3 (3rd Choice):
Standard left turnsignal/running light on motorcycle. Right turnsignal/running light mounted on sidecar as shown.
Right turnsignal on motorcycle remains attached but is electrically disconnected.
Note the differences in horizontal and vertical placement of the right and left turnsignals.
REAR VIEWS
Figure R1 (1st Choice):
Left turnsignal on motorcycle. Right turnsignal/running light on sidecar. The right turnsignal on the motorcycle will remain attached but will be electrically disconnected. Does the sidecar need a running light where shown? Can it be red or amber? Note that the motorcycle's running light is red.
Figure R2 (2nd Choice):
Standard lighting on motorcycle as shown. No lighting on sidecar.
Figure R3 (3rd Choice):
Left turnsignal on motorcycle. Right turnsignal on sidecar. Stop/running light on motorcycle and sidecar.
Which color running light would have to be used on the sidecar in this case? We feel it should be red to match the red running light on the motorcycle.
Again, the right turnsignal on the motorcycle will remain attach but will be electrically disconnected.
Figure R4 (4th Choice): Standard right/left turnsignals and stop/running light on motorcycle. Red stop/running light on sidecar.
Figure R5 (Option):
3 1/2" x 16" reflective material on back of sidecar. Is this legal with any or all of the preceeding lighting arrangements?
SIDE VIEW
Figure S1 (1st Choice):
Reflex reflector at front and rear of sidecar as shown. Note differences in height. Standard approved reflectors will remain on left side of motorcycle.
Both reflectors on sidecar meet all requirements of SAE J594e of Federal Standard 108.
SUMMARY
We urge you to seriously consider our first proposal, which we feel is the simplest, safest approach. Your speed and cooperation on returning documented answers to these questions is extremely important in order for us to remain current on our development schedule. Per Taylor Vincent, we hope to have a reply within three weeks.
If I can be of any assistance, please don't hesitate to call me at (805) 541-2900.
Rick Golde, Project Engineer
cc: DUANE ANDERSON; STEVE BERN