Interpretation ID: nht70-2.46

DATE: 12/18/70

FROM: AUTHOR UNAVAILABLE; L. R. Schneider; NHTSA

TO: Electrical Testing Laboratories, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your request for clarification of S4.4.2 of Federal Motor Vehicle Safety Standard No. 108 (Lamps, Reflective Devices, and Associated Equipment), as published in the Federal Register on October 31, 1970 (35 F.R. 16843).

You have asked the following questions:

"1. How many flashers constitute a sample for test?"

"2. How many failures, and of what types, are allowed for compliance?"

The safety standards do not specify sampling provisions or failure rates. The reference to test samples in the SAE materials referenced in Standard No. 108 were deleted in the above notice, to bring the standard into conformity with the requirements of the National Traffic and Motor Vehicle Safety Act, which requires that all items conform to the standards. It is the manufacturer's responsibility to institute a test program that will ensure that his products meet the standards.

"3. Which sentences or paragraphs in SAE J590b and SAE J345 are specifically referenced for omission?"

I attach copies of the two SAE Standards marked to show omissions.

"4. Does the statement 'tested consecutively' refer to the combination turn signal and hazard warning signal flasher or the SAE standards?"

This statement means that the combination unit is tested first to determine compliance with SAE J590b and then tested in accordance with SAE J945.

"5. * * What statement of test results is available to the testing organization?"

How you state your test results is a question to be decided between you and your clients. If you find that an item fails the standard in a particular respect, I presume that you will so state.

"6. * * Can or should all current tests on these devices be made according to the above modified procedures during this interim period prior to [the effective date of the amendment]?"

As stated above, the method and timing of a manufacturer's tests is not regulated by the Bureau. The test program should be sufficient to legally constitute are care, on a continuing basis, to ensure that all products manufactured after the effective date of a standard meet the applicable requirements.

I hope this answers your questions.