Interpretation ID: nht91-7.6

DATE: November 12, 1991

FROM: Paul Jackson Rice -- Chief Counsel, NHTSA

TO: Michael D. Incorvaia -- Manufacturing Engineering Manager, Wagner Lighting

TITLE: None

ATTACHMT: Attached to letter dated 7-3-91 from Michael D. Incorvaia to NHTSA

TEXT:

This responds further to your letter of July 3, 1991, which we informed you on August 20, will be accorded confidential treatment.

Paragraph 4.5 of SAE Standard J588e, Turn Signal Lamps, September 1970, states that "failure of one or more turn signal lamps to operate should be indicated by a 'steady on', 'steady off', or by a significant change in the flashing rate of the illuminated indicator." Electronic flashers available today provide a "significant change" in flash rate by doubling it as an outage indication. Wagner Lighting has developed a lamp outage indication that will remain within the performance parameters of Standard No. 108, but provide an outage flash rate that appears to be slightly less than 50% greater than that of normal operation. However, there will be "a recognized change in flashing rate." You have asked whether these changes may be regarded as "significant" within the meaning of SAE J588e.

Your letter indicates that the design contemplated by Wagner Electric is for application in new motor vehicles. Although SAE J588e remains in effect as a replacement equipment standard, Standard No. 108 has been amended to incorporate by reference new SAE standards for turn signal lamps, and it is these standards that now apply to turn signals on new motor vehicles. Specifically, on and after December 1, 1990, a motor vehicle must be manufactured to meet either SAE Standard J588 NOV84, Turn Signal Lamps for Use on Motor Vehicles Less Than 2032 mm in Overall Width, or SAE Standard J1395 APR85, Turn Signal Lamps for Use on Motor Vehicles 2032 mm or More in Overall Width. The outage indication requirement of SAE J588e was not adopted in either of the SAE standards, and has not been incorporated directly in Standard No. 108. This means outage indication is no longer a requirement on new motor vehicles, and that Wagner Electric, under Standard No. 108, may adopt such change flash rate as its design may call for.

We are returning the tape that you enclosed.