Interpretation ID: 21809.ztv

Mr. Charles I. Sassoon
Panor Corp.
125 Cabot Court
Hauppauge, NY 11788

Dear Mr. Sassoon:

This is in reply to your fax of June 14, 2000, to Michael Cole of our Office of Vehicle Safety Compliance.

You have had an inquiry from your customer, California Bus Sales, asking whether "they could utilize a LED beehive light classified 'side marker lamp' as a turn signal indicator." You have enclosed certificates from a test laboratory indicating that four different LED side marker lamps comply with both Federal Motor Vehicle Safety Standard No. 108 (FMVSS No. 108) and Canadian Motor Vehicle Safety Standard No. 108. We assume that the certificate is intended to cover compliance only with the side marker lamp requirements of each of the two safety standards.

The meaning of the word "indicator" is unclear. If you mean to ask whether the side marker lamp may flash when a vehicle's principal turn signal lamp system is operating, our answer is yes. Paragraph S5.5.10(b) of FMVSS No. 108 specifically allows side marker lamps to be wired for signaling purposes.

However, it seems unlikely that the LED beehive light could be used as an original equipment turn signal lamp that meets the performance requirements of FMVSS No. 108. For one thing, a turn signal's brightness is approximately 50 times that of a side marker lamp. The certificates that the LED beehive lights meet the requirements for side marker lamps is insufficient to indicate compliance with turn signal lamp requirements. Even if tests should indicate that the LED beehive light meets all the performance requirements that apply to turn signal lamps, the lamp would have to be mounted in accordance with the location and visibility requirements of FMVSS No. 108.

If you have any questions, you may call Taylor Vinson of this Office (202-366-5263).

Sincerely,

Frank Seales, Jr.
Chief Counsel

ref:108
d.7/25/00