Interpretation ID: nht87-1.50

TYPE: INTERPRETATION-NHTSA

DATE: 03/20/87

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: James R. Mitzenberg -- Project Engineer, The Flxible Corporation

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. James R. Mitzenberg Project Engineer The Flxible Corporation 970 Pittsburgh Drive Delaware, Ohio 43015

This is in reply to your letter of January 22, 1987, asking further questions of permissible lamp operations.

With reference to the deceleration warning system discussed previously in our correspondence, you have asked whether there would be a noncompliance with Standard No. 108 if the triple steady burning amber lamps are operated simultaneously with the steady burning rear stop lamps, or with the flashing turn signal lamps (either red or amber). In neither instance do we believe that an impairment of required lighting equipment world result, within the prohibition of paragraph S4.1.3.

I hope that this answers your questions.

Sincerely,

Erika Z. Jones Chief Counsel

Dear Ms. Jones

The Flxible Corporation has received your interpretation, dated December 8, 1986, concerning the operation of deceleration lights. This interpretation stated that the flashing mode of the amber deceleration lights impaired the effectiveness of the steady burning red stop lamps. Also, the amber deceleration lights must be steady burning in every mode.

Two additional issues require an interpretation from NHTSA concerning amber steady burning deceleration lights. The amber deceleratin lights would be activated steady burning when the accelerator is released and deactivated when the accelerator is depres sed. Would a noncompliance with FMVSS 108 result with the simultaneous operation of the amber steady burning deceleration lights with the following required FMKVSS 108 lights?

1. Activation of the steady burning red stop lights.

2. Activation of flashing red or amber (color depending on customer) turn signal lights.

In order to assure compliance with FMVSS 108 with an OEM installation of amber steady burning deceleration lights, we request an additional interpretation on their simultaneous operation with the normal rear stop anbd turn signal lights.

Sincerely,

James r. Mitzenberg Project Engineer