Interpretation ID: nht75-3.1

DATE: 09/04/75

FROM: AUTHOR UNAVAILABLE; R. B. Dyson; NHTSA

TO: Yamaha International Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of August 5, 1975, asking whether a prototype "stiff rubber supported turn signal" would comply with S4.3.1 of Motor Vehicle Safety Standard No. 108.

S4.3.1 requires lighting equipment to "be securely mounted on a rigid part of the vehicle." Your proposed turn signal lamp is mounted at the end of a stiff rubber bracket which is attached to the vehicle. The bracket must be considered part of the vehicle. Obviously, even with a metal mounting there will be some vibration transmitted from the motorcycle to the lamp when the engine is running. We would consider the prototype mounting to be sufficiently "rigid" to conform to the standard if the rubber mount is stiff enough so that there is little or no amplification of vibration when the engine is running.

Yours truly,

ATTACH.

August 5, 1975

Office of the Chief Counsel National Highway Traffic Safety Administration Washington, D.C.

Dear Sir:

We are considering using a stiff rubber supported turn signal on some of our future model motorcycles.

We are not sure, however, if this device complies with the requirement of S4.3.1 of FMVSS 108, which states each lamp must be mounted on a "rigid part of the vehicle".

We would like to request an interpretation of FMVSS 108 to determine if this stiff rubber supported turn signal complies with the requirement for mounting of the lamp on a rigid part of the vehicle, as specified in S4.3.1.

We are sending, under separate cover, a sample of the device in question.

If you require any additional information or materials please contact me.

Sincerely,

Russ Jura -- Legislative Analyst, Engineering Division YAMAHA INTERNATIONAL CORPORATION