Interpretation ID: aiam3740
Vice President
Peterson Manufacturing Company
4200 East 135th Street
Grandview
MO 64030;
Dear Mr. Scully: This is in reply to your letter of July 22, 1983, to Mr. Cavey of thi agency.; With respect to paragraph S4.1.1.7 of Standard No. 108 *Lamps Reflective Devices, and Associated Equipment* you have stated your understanding that that paragraph applies only to turn signal lamps manufactured between January 1, 1972 and September 1, 1973, and that turn signal lamps must now comply with SAE Standard J588e, September 1970.; Paragraph S4.1.1.7 did allow vehicular compliance with SAE J588d as a option to J588e. J588d required that any turn signal lamp used on a vehicle whose overall width was 80 inches or more have a minimum of 12 square inches effective projected luminous lens area. On the other hand, SAE J588e requires a minimum of 8 square inches effective projected luminous lens area on all single compartment rear turn signal lamps, regardless of vehicle width. However, on vehicles 80 inches or more in overall width, two turn signal lamps or compartments per side may be mounted closer together than 22 inches provided each meets single compartment photometric requirements and each has a minimum effective projected luminous lens area of 12 square inches. Thus, your understanding is correct.; I would also point out that, pursuant to Section S4.7.1 of Standard No 108, the continued manufacture of turn signal lamps meeting J588d is permissible as replacement equipment for vehicles manufactured between January 1, 1972 and September 1, 1978.; Mr. Cavey has provided the copy of BMCS regulations which is enclosed. Sincerely, Frank Berndt, Chief Counsel