Interpretation ID: 2856o
14738 Bronson Avenue
San Jose, CA 95124
Dear Mr. Apple:
This is in reply to your letter of December 29, 1987, in which you ask whether a U-Turn Indicator "is reasonable, within federal regulations or specifications, and if the Department of Transportation has interest in the concept and/or product."
Federal Motor Vehicle Safety Standard No. l08, Lamps, Reflective Devices, and Associated Equipment contains specifications for original and replacement lighting equipment. None of these specifications is for a U-turn indicator. However, a U-turn indicator is acceptable as original vehicle equipment provided it does not impair the effectiveness of the lighting equipment that the standard requires, such as turn signal lamps, headlamps, taillamps, and stop lamps. Your proposed specifications recognize the importance of differentiation between the left turn signal and the U-turn indicator, and we encourage you to minimize the possibility of impairment.
Standard No. l08 does not cover a U-turn indicator as an aftermarket device, but it is subject to the general restriction that its installation must not render inoperative, in whole or in part, any lamp, reflective device, or associated equipment that was installed pursuant to Standard No. l08. (15 U.S.C. 1397(a)(2)(A)) The legality of use of an aftermarket device of this nature would be determinable under the laws of the State in which a vehicle equipped with it is registered or operated. The American Association of Motor Vehicle Administrators, 120l Connecticut Ave. N.W., Washington, D.C. 20036, may be able to advise you further on State laws.
Accident data available to the agency does not permit us to identify specific crashes in which a vehicle is making a U-turn. However, an analysis of data from one of our files that contains information on almost 3 million crashes indicates that the general type of crash for which U-turn crashes are a subset (left-turning crashes) constitutes less than 6% of the total crash experience. Thus, we believe that the number of U-turn crashes is substantially less than the 6% represented by the broader category of crashes involving left-turning vehicles. We do not know the basis for your statement that your U-turn indicator "will probably reduce accidents involving U-turns by over thirty percent". However, the agency is interested in exploring concepts that could enhance vehicle safety. I am providing our Office of Research and Development with a copy of your letter for such further comment as may be warranted.
We appreciate your interest in safety.
Sincerely,
Erika Z. Jones Chief Counsel
CC: Michael Finkelstein
ref:108 d:4/18/88