Interpretation ID: GF004215
Giovanni Nifosi, Engineering Department Manager
MITSUBA F.N. EUROPE s.p.a.
via Aurelia Sud
Localita Mortellini
56010 Pisa
Italy
Dear Mr. Nifosi:
This responds to your e-mail of June 14, 2004, to George Feygin of my staff. You ask whether Standard J590b adopted by the Society of Automotive Engineers (SAE) or S5.1.1.20 of the Federal Motor Vehicle Safety Standard (FMVSS) No. 108 specify the motorcycle turn signal lamp voltage drop limit.
By way of background, the National Highway Traffic Safety Administration (NHTSA) issues FMVSSs applicable to new motor vehicles and motor vehicle equipment. Chapter 301 of Title 49 of the United States Code, "Motor Vehicle Safety" (49 U.S.C. 30101 et seq.), establishes a "self-certification" process under which all motor vehicle manufacturers, including motorcycle manufacturers, are responsible for certifying that their vehicles meet all applicable Federal motor vehicle safety standards.
The Federal standard applicable to lighting equipment on motorcycles is FMVSS No. 108, Lamps, Reflective Devices and Associated Equipment. FMVSS No. 108 incorporates by reference many SAE standards including those regulating turn signal lamps. S5.1.1.19 of FMVSS No. 108 specifically incorporates the voltage drop and durability requirements in SAE J590b, Automotive Turn Signal Flashers (October 1965). However, S5.1.1.20 of FMVSS No. 108 provides an exception to the voltage drop requirement in SAE J590b. Specifically, S5.1.1.20 limits the voltage drop to .8 volts as opposed to .4 or .45 volts specified in SAE J590b.
Accordingly, the voltage drop limit in S5.1.1.20 supercedes the voltage drop requirements in SAE J590b.
I hope you find this information helpful. If you need further assistance, please contact George Feygin of my staff at this address or at (202) 366-2992.
Sincerely,
Jacqueline Glassman
Chief Counsel
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