Interpretation ID: 6960
Williams & McCarthy
P.O. Box 219
Rockford, Ill. 61105-0219
Dear Mr. Gravino:
This responds to your letter of February 7, 1992, asking for an interpretation of Federal Motor Vehicle Safety Standard No. 108. Specifically, you ask whether the standard contains any requirement that the parking lamps, taillamps, and side marker lamps operate independently of the ignition switch so that when they are activated they will remain activated regardless of whether or not the ignition switch is in the on or off position. You have reviewed Standard No. 108, and reference paragraphs S5.5.3, S5.5.4, S5.5.5, and S5.5.7, copies of which you have enclosed.
The answer is no. Under paragraph S5.5.5, the vehicular hazard warning signal operating unit is required to operate independently of the ignition switch, but no other lamp is required by the standard to do so.
Sincerely,
Paul Jackson Rice Chief Counsel
ref:108 d:3/5/92