Interpretation ID: aiam0434
Manager
Electrical/Electronic Division
Electrical Testing Laboratories
Inc.
2 East End Avenue
New York
NY
20021;
Dear Mr. Pracejus: Thank you for your letter of September 8, 1971, concerning the recen amendment of Standard 108 concerning turn signal and hazard warning flashers (36 F.R. 17343, August 28, 1971).; You noted that test-condition temperatures are listed withou tolerances, and asked what tolerance is acceptable for testing.; In the case of motor vehicle safety standards, the testing that manufacturer may perform or have performed on its products is not an end in itself, but is done to enable the manufacturer to certify that the products meet the required performance levels under the specified conditions. Thus, the requirement that a product meet or exceed certain values at 75 degrees F. refers to a legal conclusion that is to be drawn from appropriate testing, and no tolerance is necessary or appropriate in the text of the standard. In practical terms, it is up to the manufacturer to determine what tests will enable him to certify his products as conforming. Normally, this is done by testing his products under slightly more adverse conditions than those specified in the standard. If, for example, higher temperatures constitute more adverse conditions for a flasher, the laboratory should test at a temperature slightly higher than that specified. In sum, the testing should be sufficient to support the *conclusion* that, if tested under the specified conditions, the product would perform as required.; Sincerely, Lawrence R. Schneider, Chief Counsel