Interpretation ID: aiam4147
M.D.
84 Haight Avenue
Poughkeepsie
NY 12603;
Dear Dr. Delphin: This is in reply to your letter of April 2, 1986, enclosing description of your device to improve car signals, and asking about the regulations applicable to it.; According to the information that you furnished, the device 'cancel turn signal indicators immediately upon the completion of a turn'. The purpose of the device is to eliminate 'the need for drivers to cancel the signal manually when the turn is not sharp enough to activate the standard switch'. The effect of the device is 'to reduce the incidence of traffic accidents due to misinterpreted turn signals'.; As you know, pursuant to Federal Motor Vehicle Safety Standard No. 10 *Lamps, Reflective Devices, and Associated Equipment*, passenger cars manufactured on or after January 1, 1973, have been required to have self- cancelling turn signal indicators. However, there are no performance requirements for the self-cancelling feature. As a general rule, motor vehicle lighting equipment not required by Standard No. 108 is permissible as original equipment provided that it does not impair the effectiveness of lighting equipment required by the standard, and as aftermarket equipment if its installation can be accomplished without creating a noncompliance. The device as you have described it does not appear to impair the effectiveness of the turn signal operating unit, or create a noncompliance with Standard No. 108 (the requirements of SAE Standard J589 *Turn Signal Operating Unit*, April 1964, which is incorporated by reference). Since Standard No. 108 does not preclude its use, the question of its legality is therefore determinable under the laws of each State where it will be used.; Although there is no Federal safety standard that applies to it, th device is an item of motor vehicle equipment subject to the notification and remedy provisions of the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1381, 1411) if its manufacturer or this agency determines that it incorporates a safety related defect.; I hope that this answers your question. Sincerely, Erika Z. Jones, Chief Counsel