Interpretation ID: nht71-4.49

DATE: 11/16/71

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

TO: The Flxible Company

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of October 22 asking whether the "hoodlum warning system" requested by the city of Boston (MBTA) would conform to Federal Motor Vehicle Standard No. 108, Lamps, Reflective Devices, and Associated Equipment.

Paragraph S3.5 of Standard No. 108 permits "normally steadily-burning lights [to] be capable of being individually flashed for signalling purposes" on motor vehicles manufactured before January 1, 1972. Therefore the hoodlum warning system is currently permissible under Standard No. 108.

However, a new requirement effective January 1, 1972, would prohibit the installation of this system on vehicles manufactured on or after this date. Paragraph S4.6 of Standard No. 108 states:

"Where activated

(a) Turn signal lamps, hazard warning signal lamps, and school bus warning lamps shall flash;

(b) All other lamps shall be steady-burning except that means may be provided to flash headlamps and side marker lamps for signalling purposes." (emphasis added)