Interpretation ID: aiam3443
Manager (R&D)
Bajaj Auto Limited
Adurdi
Poona - 411 035 India;
Dear Mr. Keshav: This is in reply to your letter of July 7, 1981 asking for a 'exemption' from the requirement of paragraph S4.5.6 of Motor Vehicle Safety Standard No. 108 that an illuminated pilot indicator be provided in each vehicle equipped with a turn signal operating unit.; In your opinion, the front turn signal lamps mounted on the handlebar of certain motor scooters that you manufacture can serve as pilot indicators, if a front turn signal lamp fails to operate, the failure is readily apparent to the operator, if a left turn signal lamp fails, there is an 'appreciable change in the flashing rate' of the front lamp.; We concur in your interpretation. Although S4.5.6 does require th indicator, SAE Standard J588e *Turn Signal Lamps*, September 1970, incorporated by reference, requires it only if turn signal lamps are not readily visible to the driver. Because the operability of both front and rear turn signal lamps on the vehicles you described may be confirmed by the front turn signal alone, the front lamp is the functional equivalent of a turn signal indicator, and a separate indicator need not be provided.; As this is a matter of long-standing interpretation of Standard No. 10 we have no plans to amend S4.5.6 to incorporate it.; Sincerely, Frank Berndt, Chief Counsel