Interpretation ID: nht88-1.47
TYPE: INTERPRETATION-NHTSA
DATE: 02/19/88
FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA
TO: The Honorable Charles Wilson
TITLE: FMVSS INTERPRETATION
ATTACHMT: 6/19/89 letter from Stephen P. Wood to Rod Willaredt (A33; Std. 108); 5/17/89 letter from Rod Willaredt to Taylor Vinson: 4/18/88 letter from Erika Z. Jones to Wayne Apple (Std. 108); 7/11/88 letter from Erika Z. Jones to William J. Stephenson (Std. 108)
TEXT: The Honorable Charles Wilson House of Representatives Washington, D.C. 20515
Dear Mr. Wilson:
This is in response to your letter of December 9, 1987, to Ms. Brenda Brown, Office of Congressional Affairs, Department of Transportation, which has been forwarded to this Office for reply. Unfortunately/ the Department has no record of receiving your p revious letter of August 19, 1987.
You have written on behalf of your constituent Mr. W. P. Brandon of Palestine who has designed a Wide Right Turn signal for installation on the rear of trailers. The device consists of the words Wide Right Turn and an arrow, in black on a caution yellow background. The device is attached to the lower right rear of a trailer, and flashes when the turn indicator is positioned for a right turn. Mr. Brandon asks three questions with respect to his device, which I shall answer shortly.
Preliminarily let me note that the applicable Federal law and regulation are, respectively, the National Traffic and Motor Vehicle Safety Act of 1966, and Federal Motor Vehicle Safety Standard No. 108 Lamps Reflective Devices and Associated Equipment. St andard No. 108 permits a supplementary lighting device such as Mr. Brandon's as original trailer equipment if it does not impair the effectiveness of the lighting equipment that Standard No. 108 requires, such as the standard turn signal system. The Vehi cle Safety Act permits it as aftermarket trailer equipment if its installation by a person other than the trailer owner does not render inoperative, wholly or in part, equipment installed on the trailer pursuant to Standard No. 108 or any other safety st andard.
With these general remarks in mind, we reach the three questions that Mr. Brandon asked.
"1. Is there any rule regarding the placement of a flashing 'Wide Right Turn' signal on the lower right rear of a trailer?" The answer is no, as long as there is no impairment of the effectiveness of the other rear lamps (i.e., the standard turn signal must continue to operate when the lever is in the position indicating a right turn, but the wide turn signal should not opera te when the hazard warning signals (which operate through the turn signal lamps) are on).
"2. Can the signal be black letters on a safety yellow background or should it be another color"?
The agency does not prescribe the color of supplementary lighting devices, and color is subject only to the "impairment" restriction. Required lighting equipment on the rear of trailers may be white (back up lamps), amber (turn signals), or red (the alte rnative color for turn signals, and the required color for taillamps and stop lamps). I am unsure what "safety yellow" is, but it would not appear to impair the effectiveness of the red, amber, or white lamps on the trailer's rear.
"3. Are there any restrictions on manufacturing of the signal insofar as materials or construction are concerned?"
There are no Federal restrictions or requirements. However, supplementary lighting devices such as Mr. Brandon's are subject to regulation in all their aspects by the States in which they will be sold and used. We are not conversant with State regulation s on this subject, and suggest that, for further advice, Mr. Brandon contact the American Association of Motor Vehicle Administrators, 1201 Connecticut Ave., N.W., Washington, D.C. 20036.
We appreciate Mr. Brandon's interest in safety, and your writing us with respect to his "Wide Turn Signal" device.
Sincerely,
Erika Z. Jones Chief Counsel
WEB MARKETING COMPANY P. 0. Box 1609 Palestine, TX 75801
August 17, 1987
Mr. Larry Murphy 2265 H. O. B. Washington, D. C. 20515
Dear Mr. Murphy,
As per our telephone conversation today, the following is a discription of the "Wide Right Turn" signal I have designed. The signal is approximately 10 inches by 12 inches by 1 inch thick. The words and arrow are in black on a caution yellow background. The signal will be attached by bolts or welding to the lower right hand corner of the trailer. The signal will flash on and off when the driver positions his turn indicator for a right turn. (See attached photograph).
What I need to know from the U.S. Department of Transportation, National Highway Traffic Safety Administration following: 1. Is there any rule regarding the placement of a flashing "Wide Right Turn" signal on the lower right rear of a trailer.
2. Can the signal be black letters on a safety yellow back-ground or should it be in another color.
3. Are there any restrictions on manufacturing of the signal insofar as materials or construction are concerned.
As I stated to you on the phone I am working with Patent Attorneys in Houston regarding Patent Application of this signal devise.
Mr. Murphy, your assistance with the D.O.T. in getting me some answers will be greatly appreciated.
Yours very truly,
W. P. Brandon WEB MARKETING COMPANY (214)538-2512
WPB/eb
Ms. Brenda Brown Office- Congressional Affairs Room 1046 (I-25) Department of Transportation 400 7th Street, S.W. Washington, D.C. 20590
Dear Ms. Brown:
We wrote to the Department on August 19, 1987, on behalf of Mr. W.P. Brandon of Palestine, Texas, regarding a "Wide Right Turn" signal for trailer trucks, which he had designed.
I would appreciate it if you will provide us with the status of action on this matter. We are enclosing copies of the prior correspondence for ease of reference.
Thank you for your assistance.
Sincerely,
Charles Wilson
CW:lm
August 19, 1987
Ms. Brenda Brown Office- Congressional Affairs Room 1046 (I-25) Department of Transportation 400 7th Street, S.W. Washington, D.C. 20590
Dear Ms. Brown:
Enclosed is a letter from Mr. W.P. Brandon of Palestine, Texas, regarding a "Wide Right Turn" signal for trailer trucks which he has designed.
As you may note, Mr. Brandon has certain questions that he has asked our assistance in getting answers. Any information which you may provide to answer these questions would be appreciated. Thank you for your consideration.
Sincerely,
Charles Wilson
CW:lm