Interpretation ID: aiam3778
President
TWI Inc.
14525 Bessemer Street
Van Nuys
CA 91411;
Dear Capt. Perzinsky: This is in reply to your letter of October 14, 1983, to Mr. Vinson o my staff regarding your F-S- 700 A flasher. The device is essentially a slender bar of lights mounted on the rear panel shelf of a passenger car. The left and right sides blink to indicate turns in the appropriate direction. The entire bar lights up when the brake pedal is applied. You ask for our 'approval' of this device.; The Federal motor vehicle safety standard on lighting forbids th installation of motor vehicle equipment that impairs the effectiveness of lighting equipment required by the standard. Stop lamps are required by the standard. They must be red. They must go on when the brake pedal is applied. The stop signal put out by the F-S-700 flasher is amber, not red. Therefore, an amber signal coming on at the same time as a red one would impair the effectiveness of the red stop lamp by creating confusion.; The Federal lighting standard allows either amber or red turn signa lamps. There is obviously a potential for confusion if your amber light device is on a vehicle whose turn signals are red. But an even greater problem with interior-mounted lamps, whatever their color, is the reflection that they cause in the rear glass, particularly when it's raining or snowing, interfering with the rear vision of the vehicle's driver.; For the reasons given above the F-S-700 A flasher causes us som concern. Further, you should investigate whether the laws of the jurisdiction where you wish to sell this device will permit its installation and use.; Sincerely, Frank Berndt, Chief Counsel