Interpretation ID: 17380.ztv

Herr P. Binder
ITT Automotive Europe
Stuttgarter Strasse 119
74321 Bietigheim-Bissingen
Germany

Dear Mr. Binder:

This is in reply to your fax of February 23, 1998, asking several questions about reflex reflectors.

As we understand your first question, a vehicle would be designed with two rear side reflex reflectors, one on the body and one on the tailgate. You ask whether it is permissible to mount two reflectors on each side, and whether each reflector is required to meet the requirements of Federal Motor Vehicle Safety Standard No. 108.

We assume that both reflectors would be red in color. Table IV of Standard No. 108 specifies that a red reflex side reflector be located "as far to the rear as practicable." Thus, the reflex reflector mounted on the tailgate would be the reflector located "as far to the rear as practicable," and the reflector that is required to comply with Standard No. 108. It is permissible to add a second reflector. This would be the reflector located on the body. Supplementary reflectors need not comply with Standard No. 108.

Your second question is whether Standard No. 108 permits mounting reflex reflectors only on the tailgate. Yes, that is acceptable as long as the reflector is located in accordance with Table II.

Your third question relates to a two-compartment lamp containing stop and turn signal bulbs. In the event that either bulb fails, you ask whether there is "any regulation which must be passed."

The only requirement that must be met under Standard No. 108 is that failure of the turn signal bulb be brought to the attention of the vehicle operator by the turn signal pilot indicator, an item of motor vehicle equipment required on new vehicles by the standard.

Under the fact situation in your final question, the stop lamp is optically combined with the turn signal lamp. You have asked which lamp will have priority if the stop lamp and hazard warning signal lamp are activated simultaneously or in succession. The SAE standards for stop lamps and turn signal lamps that are incorporated by reference in Standard No. 108, state that "when a stop signal is optically combined with the turn signal, the circuit shall be such that the stop signal cannot be turned on if the turn signal is flashing." Because hazard warning signal lamps operate through the turn signal lamp system, many vehicles are wired so that the stop signal cannot be turned on if all the turn signal lamps (i.e., the hazard warning lamp system) are flashing. However, Standard No. 108 and the SAE have no requirements per se for the hazard warning system. This means that a vehicle may be wired with a separate hazard warning system circuit so that it is subordinate to, and overriden by, the stop signal when both are operated simultaneously.

But the stop lamp must not override the individual turn signals when they are operating simultaneously, or if the brake pedal is applied when the individual turn signals are flashing.

Sincerely,
John Womack
Acting Chief Counsel
ref:108
d.5/22/98