Interpretation ID: aiam3665
J.V.R. Enterprises
8511 N. Canterbury Avenue
Sun Valley
CA 91352;
Dear Mr. Wirffel: This is in reply to your letter of February 6, 1983, to Mr. Vinson o my staff regarding the legality under Federal Motor Vehicle Safety Standard No. 108 of your 'Safe-T- Signal' directional indicator. The signal, an 8-inch amber arrow, is located under the right side of a semi-trailer, approximately at mid point, and is intended to warn vehicles in the adjacent right traffic lane that the semi-trailer makes wide right turns. The system supplements the trailer's existing turn signal system, as we understand it.; There is nothing in Standard No. 108 that prohibits use of your syste as it does not appear to impair the effectiveness of the lighting equipment, such as turn signals, required by Standard No. 108 as original equipment. However, you must insure that it is permitted in States in which the device is likely to be used.; We note the statement in your letter that the amber arrow is 'D.O.T approved' and in your descriptive sheet as well, plus the statement that it 'Conforms to applicable federal motor vehicle standards (C.H.P. approved).' This is legally incorrect, as the U.S. Department of Transportation does not 'approve' lighting equipment, nor does Standard No. 108 specify requirements with which a supplementary turn signal system conform. If you wish to assure prospective purchasers that Federal requirements are not being violated, we would prefer you use a phrase such as 'Permissible under Federal Motor Vehicle Safety Standard No. 108.'; Sincerely, Frank Berndt, Chief Counsel