Interpretation ID: nht73-6.4

DATE: 11/12/73

FROM: AUTHOR UNAVAILABLE; Robert L. Carter; NHTSA

TO: Honorable John B. Conlan, U.S. House of Representatives

COPYEE: SEC. REP. DUNN; DR. KAYE; J. L. LEYSATH; MR. VINSON

TITLE: FMVSS INTERPRETATION

TEXT: This will supplement the Bureau of Motor Carrier Safety's reply of October 30, 1973, to your letter of September 21, 1973, to the Interstate Commerce Commission, concerning Mr. William H. Arendell's automatic light-blinking device for truck signaling. The Bureau has referred your letter to us for further reply.

Enclosed for your constituent's information is a copy of Federal Motor Vehicle Safety Standard No. 108, entitled, "Lamps, Reflective Devices and Associated Equipment." The effect of paragraph S4.6 of the standard is to prohibit the use of automatic flashing clearance lamps for signaling purposes on vehicles manufactured on or after January 1, 1972. The term "flash" is defined (paragraph S3) as "a cycle of activation and deactivation of a lamp by automatic means continuing until stopped either automatically or manually."

It appears that the device described in your constituent's letter falls within the prohibition of Standard No. 108, and could not be used as original equipment on vehicles. Its use as an aftermarket device would be subject to regulation by the individual States.

I trust the above information will be of interest to Mr. Arendell.

2 ENCLS. CONSTITUENT'S LETTER STD. NO. 108