Interpretation ID: nht79-1.17

DATE: 11/05/79

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Bajaj Auto Limited

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. M. S. Keshav Manager - Research & Development Bajaj Auto Limited Bombay Poona Road Akurdi - Poona - 411 035 India

Dear Mr. Keshav:

This is in reply to your letter of September 2, 1979, to Francis Armstrong asking for an interpretation of Federal Motor Vehicle Safety Standard No. 108. SAE Standard J588e August 1970 is the referenced standard for turn signal lamps. Paragraph 4.2 of J588e requires that as mounted on the vehicle "The optical axis (filament center) of the front turn signal lamp shall be at least 4 inches from the inside diameter of the retaining ring of the headlamp unit providing the lower beam". You mentioned that on some motorcycles sold in the United States this requirement is satisfied only with the handlebar in the straight ahead position but not when turned to the full lock position. You asked whether this complies with Standard No. 108.

Table IV specifies that the minimum edge to edge separation between the headlamp and turn signal lamp on motorcycles is 4 inches. Most manufacturers have interpreted this requirement to mean that the separation is permanent, and have supplied turn signals that are mounted stationary with the headlamp, and that turn with it so that the separation distance is maintained. Therefore, the configuration you describe would not comply with Standard No. 108 because Federal requirements for location and mounting of lighting equipment are intended to apply to a vehicle under all its operating conditions.

Sincerely,

Frank Berndt Chief Counsel

BAJAJ AUTO LIMITED

RD 39363 Date: 2nd September 1979.

Mr. Fransis Armstrong, Director Office of the Vehicle Safety Compliance Enforcement U.S. Department of Transportation National Highway Traffic Safety Administration Washington, D.C. 20590 U.S.A.

Dear Sir,

We refer to FMVSS Part 571, S108 Table IV/SAE J 588c 4.2 standand. As per the standard the minimum edge to edge separation distance between turn signal lamp and head lamp should be 4 inches. We have come across some vehicles sold in U.S.A. wherein this dimension is satisfied only in the straight ahead driving position i.e. when the handle bar is kept straight. In such vehicle, since the turn signal flasher lamps are fitted in the front on the non steered portion of the vehicle, the distance between the turn signal flasher lamp and the head lamp is almost zero when the handle bar is turned to the full lock position. Please let us know whether this is permissible as per the regulation.

Thanking you,

Yours faithfully, For BAJAJ AUTO LIMITED

M. S. KESHAV MANAGER - RESEARCH & DEVELOPMENT