Interpretation ID: aiam3109
Vice President
Engineering
The Grote Manufacturing Company
State Rt. 7 - P.O. Box 766
Madison
IN 47250;
Dear Mr. Newman: This is in reply to your letter of August 23, 1979, to the former Chie Counsel Joseph J. Levin, Jr. You have asked whether a double-faced turn signal front side marker lamp 'meets the intent' of Motor Vehicle Safety Standard No. 108, and you enclosed a sample of the lamp for our inspection.; You have quoted paragraph 3.4 of SAE Standard J588e, September 1970 which states 'the flashing signal from a double faced signal lamp shall not be obliterated when subjected to external light rays from either in front or behind at any and all angles.' It is not possible to make a definitive statement about your lamp without actually subjecting it to a representative external light source such as the headlamps of a vehicle in proximity to the vehicle to which the lamp is mounted, but its design appears adequate to meet the intent of paragraph 3.4. Any changes in design of the lenses or baffling from that of the sample lamp submitted, however, might transmit more light from external sources and may not meet paragraph 3.4.; We would also like to observe that since the side marker signal use the front and rear lenses of the turn signal in a single compartment a high intensity ratio of turn signal to side marker signal will be needed if the steady burning light from the side marker lamp is not to obscure the darker portion of the turn signal lamp.; Sincerely, Frank Berndt, Chief Counsel