Interpretation ID: nht90-3.47

TYPE: Interpretation-NHTSA

DATE: August 2, 1990

FROM: Samuel Kimmelman -- Engineering Product Manager, IDEAL Division, EPICOR Industries, Inc.

TO: Paul Jackson Rice -- Chief Counsel, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 8-31-90 from P.J. Rice to S. Kimmelman (A36; Std. 108)

TEXT:

When a new car, light truck or van is purchased and delivered to the buyer with a dealer installed trailer hitch and associated wiring, it is our understanding that at the time of delivery the vehicle must comply with all applicable Federal Motor Vehicle Safety Standards.

We further interpret the Standards to require the following:

1. The turn signal flasher must be certified as meeting the FMVSS-108 requirements of a variable load turn signal flasher, over a minimum load equal to that of the vehicle turn signal load and a maximum load equal to that of the vehicle plus the trailer .

2. The hazard warning flasher must be certified as meeting the require- ments of FMVSS-108 over a load range of 2 lamps to the combined hazard warning loads of the vehicle plus the trailer.

3. The requirement to provide turn signal outage indication is voided due to the trailer towing capability of the vehicle.

Please inform us if the interpretations noted above agree with those of the Department of Transportation.