Interpretation ID: aiam2972
President
Vespa of America Corporation
355 Valley Drive
Brisbane
CA 94005;
Dear Mr. Porrati: We have received your letter of January 22, 1979, petitioning for determination that a possible noncompliance with Federal Motor Vehicle Safety Standard No. 108 is inconsequential as it relates to motor vehicle safety.; This is to inform you that upon review of Mr. Levin's letter to you o March 14, 1978, and examination of the turn signal system employed on Vespa motor scooters, we have determined that there is no failure to comply with the standard and your petition is moot.; Vespa brought to our attention the fact that S4.5.6 of Standard No. 10 requires each vehicle equipped with a turn signal operating unit to have an illuminated pilot indicator but SAE Standard J488e, incorporated by reference, requires it only if turn signal lamps are not readily visible to the driver. Mr. Levin informed Vespa that, if all turn signal lamps were readily visible to the driver, no pilot indicator was necessary. Mr. Levin continued by saying:; >>>'If the driver must turn his head to the rear to check the operatio of turn signal lamps, then those lamps are not 'readily visible to the driver' and a turn signal indicator must be provided.'<<<; You have now informed us that you believe the turn signal system o Vespa motor scooter manufactured between March 1975 and the latter part of 1977 'are the functional equivalent of turn signal indicators', specifically; >>>'The turn signal systems ... are designed so that in the event of failure of either rear turn signal lamp, the appropriate front turn signal lamp will flash at three times the normal rate. As the front turn signal lamps and their flash rates are readily visible at all times to the operator, any turn signal malfunction will be readily apparent to the operator.'<<<; We agree with your conclusion. The rapid flash rate will indicate th presence of a problem in either the front or rear turn signal system and the equivalent of a turn signal indicator appears to have been provided.; Sincerely, Frank Berndt, Acting Chief Counsel