|Mr. Glenn Panes
921 Todville Road
Seabrook, TX 77586
Dear Mr. Panes:
This is in reply to your e-mail of April 7, 1999.
You are interested in buying an aftermarket combination stop/turn
signal lamp which has a clear lens and red and amber bulbs. You ask
whether the lamps are legal to use. Apparently your local police do not
object, but you are concerned about being stopped somewhere else.
The answer to your question depends on a number of factual issues, as
well as the laws of local and state jurisdictions. Therefore, this is not
a question we can fully answer for you.
We establish the Federal motor vehicle safety standards that apply to
new motor vehicles and vehicle equipment from the time of manufacture
until time of first sale. One of these, Federal Motor Vehicle Safety
Standard No. 108 Lamps, Reflective Devices and Associated Equipment
specifies the lighting equipment a vehicle must have when manufactured,
and the performance of this original equipment and the aftermarket
equipment intended to replace it. We can tell you how this standard
relates to the aftermarket lamp you describe.
equipment is required to comply with Federal new-equipment requirements,
and be certified as complying. We are unable to tell whether the
combination stop/turn signal lamp you describe complies but would like to
make a few comments on it. Under Standard No. 108, a turn signal lamp is
permitted to emit amber light. The amber light may be provided by either
an amber lens and clear bulb, or an amber bulb and a clear lens. The
question, then, is whether the turn signal lamp meets Standard No. 108's
Standard No. 108 has incorporated by reference the Society of
Automotive Engineers (SAE) specifications for amber turn signal lamps.
SAE specifications for stop lamps are also incorporated by reference in
Standard No. 108. These specifications require the use of special bulbs
for testing purposes. However, SAE
has no specifications for red bulbs. Thus, it may not be possible
for manufacturers to certify that a lamp meets all applicable Federal
motor vehicle safety standards. Nevertheless, if the manufacturer has
marked the replacement lamp with a "DOT" symbol (or certified
its conformance on its container), you may regard that as its
representation that the lamp meets all applicable Federal requirements.
This certification, however,
does not mean that the original equipment lamp can be removed and the new,
different one substituted without causing a noncompliance with Standard
No. 108. The standard requires vehicles to have two red reflex
reflectors on their rear, and one on each side at the rear. In many
instances, these reflectors are incorporated into red rear combination
lamp lenses. Thus, depending on the location of red reflex reflectors on
the side and rear of the car, substitution of a white-lensed stop lamp
might remove this desirable safety feature.
Even if the lamp were certified as complying, if installation of the
lamp you are interested in would result in removal of the only reflex
reflectors on the side and/or rear, there would be a violation of Federal
law if this work was performed by a manufacturer, distributor, dealer, or
motor vehicle repair business, and if the modifier did not add two reflex
reflectors to the rear of the car. However, this prohibition does not
apply to you, if you, the vehicle's owner, substitutes the lamp.
Nevertheless, it is possible that you could be cited somewhere for a
violation of local laws if the vehicle lacks rear reflex reflectors. As a
general rule, we urge caution in replacing any lighting equipment with
Some new motor vehicles may be equipped with original equipment rear
combination lamps that have clear lenses, but the red color of the light
emanating from these lamps is produced by a clear bulb projecting through
a red inner plastic lens. Such lamps do not use red bulbs and are
certified as complying.
If you have any further questions, you can contact Taylor Vinson of
this Office, either by phone (202-366-5263), or by e-mail (Tvinson@nhtsa.dot.gov).
Frank Seales, Jr.