Interpretation ID: nht78-4.25

DATE: 03/14/78

FROM: AUTHOR UNAVAILABLE; Joseph J. Levin, Jr.; NHSTA

TO: Vespa of America Corporation

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. Donald Beyer National Service Manager Vespa of America Corporation 322 East Grand Avenue South San Francisco, California 94080

Dear Mr. Beyer:

This is in reply to your letter of October 24, 1977, requesting an interpretation whether motorcycles with turn signals are required to have turn signal indicators. You noted that Table 2 of Standard No. 123 does not include a turn signal indicator as a motorcycle display, while there appear to be conflicts within Standard No. 108, S4.5.6 requires an indicator but SAE Standard J588c (incorporated by reference in Standard No. 108) requires an indicator only if turn signal lamps are not readily visible to the driver.

Although S4.5.6 does require each vehicle equipped with a turn signal operating unit to have an illuminated pilot indicator, in my view a manufacturer who eliminated them in reliance upon J588c would not fail to comply with the standard if all signal lamps are readily visible to the driver.

However, we interpret "readily visible to the driver" to mean visible to the driver when facing forward in the driving position. Motorcycles are required to have separate turn signal lamps at or near the front, and at or near the rear of the vehicle. If the driver must turn his head to the rear to check the operation of his rear turn signal lamps, then those lamps are not "readily visible to the driver" and a turn signal indicator must be provided. While Standard No. 123 itself in Table 3 does specify requirements for identification of turn signal "control and display identification", it does not provide requirements for illumination ana operation of the display in Table 2, as you noted.

Sincerely, Joseph J. Levin, Jr. Chief Counsel