Interpretation ID: 20935.ztv

Scott R. Elkin, D.O.
P.O. Box 4595
Austin, TX 78765

Dear Mr. Elkin:

This is in reply to your letter of November 1, 1999, informing us that there is no audible indication when the turn signal system in your 1997 Saab is operating. Further, you report that the "light signals are often obscured by the steering wheel." You have asked us for a response.

Your Saab was required to comply with Federal Motor Vehicle Safety Standard No. 108, "Lamps, Reflective Devices and Associated Equipment," upon its manufacture and sale to you. Standard No. 108 requires a passenger car to be equipped with a turn signal system. The turn signal system in your car is required to meet the specifications of SAE Standard J590b, "Automotive Turn Signal Flashers," October 1965. These specifications have been incorporated by reference into Standard No. 108. SAE J590b requires a "visible pilot indicator" to be incorporated in the turn signal system. Federal Motor Vehicle Safety Standard No. 101, "Controls and Displays," requires the pilot indicator to be a pair of arrows that illuminate with a green color in the direction of the turn when the turn signal system is activated. Standard No. 101 requires that the indicator be visible to a vehicle operator when the driver is seated at the wheel and the driver's seat belt is fastened. We interpret this to require that the indicator be visible when the steering wheel is in the straight ahead position. There is no requirement that the indicator be visible under all operating conditions.

Standard No. 108, through SAE J590b, also permits, but does not require, an audible signal indicator when the turn signals are operating. For many vehicles, replacement turn signal flashers are available that are intended to be audible. You may wish to check your local auto parts retail stores to see if one is available for your car.

In summary, although the turn signal operating indicators in your car may not satisfy you, your vehicle appears to comply in this respect with Federal requirements.

If you have further questions, you may call Taylor Vinson of this Office (202-366-5263).

Sincerely,
Frank Seales, Jr.
Chief Counsel
ref:108
d.3/30/00