Interpretation ID: nht71-5.45

DATE: 09/16/71

FROM: AUTHOR UNAVAILABLE; L. R. Schneider; NHTSA

TO: Electrical Testing Laboratories, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of September 8, 1971, concerning the recent 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 without tolerances, and asked what tolerance is acceptable for testing.

In the case of motor vehicle safety standards, the testing that a 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.

RB

cc

ELECTRICAL TESTING LABORATORIES, INC.

September 8, 1971

Docket Section National Highway Traffic Safety Administration

Re: Docket No. 71-12588

69-18, notice 5

We have reviewed the above mentioned notice to amend Motor Vehicle Safety Standard No. 108 relative to automotive turn signal and hazard warning signal flashers. We find that in Section S4.6.1.3, subparagraphs (b)(ii) and (c)(ii) have been interchanged relative to current testing procedures. We also note that paragraph S4.6.1.3, subparagraph (c)(iv) 11 volts is shown as 11.00. The additional zero indicates accuracy beyond normal testing procedure.

We find that in all cases the ambient temperature is shown as 75 degrees F. without a tolerance. We would like to ask what tolerance is acceptable for testing.

W. Glenn Pracejus Manager Electrical/Electronic Division