Interpretation ID: nht69-2.39

DATE: 09/12/69

FROM: AUTHOR UNAVAILABLE; C. A. Baker; NHTSA

TO: The Flexible Company

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of August 21, 1969, to Mr. George C. Nield, Acting Assistant Director, Motor Vehicle Safety Performance Service, concerning the requirements of Federal Motor Vehicle Safety Standard No. 108 with respect to activation of stop lamps when the emergency brakes are applied.

Paragraph S3.4.4 of Standard No. 108 specifies that "Except as provided in S3.4.4.1 through S3.4.4.3 stop lamps shall be actuated upon application of any service or emergency broken." The emergency-parking brakes as described in the 2nd paragraph of your letter are not considered "emergency" brakes within the weaning of paragraph S3.4.4 of Standard No. 108. Therefore, actuation of stop lamps need not be provided upon application of such brakes. I should point out, however, that the Bureau now has under development a proposed standard for brakes which will be applicable to trucks. If under this proposed standard, the emergency-parking brakes as used on your vehicles are defined as "emergency" brakes, then the requirement of paragraph S3.4.4 of Standard No. 108 will be applicable.