Interpretation ID: nht79-1.15
DATE: 10/01/79
FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA
TO: Leo Bachynsky -- Laboratory Manager, R.E. Dietz Co.
TITLE: Emergency Warning Lamp - Use of Relfex
ATTACHMT: 8/21/79 letter from Leo Bachynsky to NHTSA
TEXT:
Dear Mr. Bachynsky:
This is in reply to your letter of August 21, 1979, asking for an interpretation of Federal Motor Vehicle Safety Standard No. 108 as it may apply to a proposed new product of your company.
This product, as you have described it, is a bi-directional Emergency Vehicle Warning Lamp, with one lens facing to the front of the vehicle, and one to the rear. Each lens contains a 5/8 inch wide band of reflex reflector around its periphery. The lamp would be supplied in a variety of colors (red, blue, yellow) and a similar device, less the reflex reflector area, is currently in production.
You have asked whether the inclusion of the reflex reflector in the device, "impairs the effectiveness of the required equipment" within the prohibition of S4.1.3. You have also asked whether the equipment and location tables of Standard No. 108 restrict the use of a red reflex reflector facing the front and yellow reflex reflector facing the rear.
The determination of whether installation of additional lighting devices impairs the effectiveness of required equipment may be made either by the vehicle manufacturer or by NHTSA. Since your company already markets an emergency vehicle warning lamp we shall assume for purposes of discussion that vehicle manufacturers have determined that the lamp as currently manufactured does not impair other lighting equipment. Nor does it appear to us that the addition of the limited reflex reflector area would contribute to a degradation of the effectiveness of required lighting equipment, although a definitive judgment could not be made until the lamps were actually installed on a vehicle. The tables do not apply to supplementary lighting equipment such as your emergency lamp though the agency believes there is less likelihood of confusion if the public associates amber lighting devices with the front part of a vehicle, and red ones with the rear.
Sincerely,
Frank Berndt Chief Counsel
August 21, 1979
Chief Council NHTSA 400 Seventh Street S.W. Washington, D.C. 20590
Dear Sir:
Our company is presently developing a new product and is in need of a clarification concerning the legality of the proposed product as it pertains to FMVSS 108.
Briefly, the device is a bi-directional Emergency Vehicle Warning Lamp consisting of two 7-1/2 inch diameter lenses. The lenses contain a 5/8 inch wide band of reflex reflector around their periphery. The two lenses are locked to a mounting flange by a special locking feature and two screws. When mounted, the device will have one lens facing to the front of the vehicle and the other to the rear. The device is to be supplied in a variety of colors, red, yellow, blue, and can be used in either a steady or flashing state.
We manufacture a similar device less the reflex reflector area and previous sales data indicates the majority of the market for this type of device is for tow trucks and utility company vehicles.
We are aware of the fact that Emergency Warning Lamps are not regulated by FMVSS 108 or any other Federal standard, but rather our questions concern the reflex reflector area in the device.
The areas that need clarification with respect to our application are the following:
1. Paragraph S.4.1.3 of FMVSS 108 - "No additional lamp, reflective device or other motor vehicle equipment shall be installed that impairs the effectiveness of the equipment required by this standard."
Does this Paragraph S.4.1.3. restrict the use of the reflex reflector in our proposed device as imparing effectiveness of required equipment?
2. Do Tables 1-4 of FMVSS 108 "Required Equipment for Motor Vehicles" and "Locations of Required Equipment" restrict the use of a red reflex reflector facing the front and yellow reflex reflector facing the rear of the vehicle?
An early reply will be appreciated.
Enclosed is our blueprint of the subject device and an advertising poster showing exact application of the intended device.
Sincerely,
Leo Bachynsky Laboratory Manager
LB/sg Enclosure (2)