Are there requirements for strobe, beacon and other forms of auxiliary lighting?

From an NTEA member We are a truck equipment distributor and routinely get requests from our customers to install strobe lights. What are the requirements regarding these types of lights? In general, strobe lights, beacons and other forms of auxiliary lighting fall outside of the Federal Motor Vehicle Safety Standards (FMVSSs). The National Highway Traffic Safety Administration (NHTSA) does not regulate this type of lighting, so consequently, they are not included in the FMVSS requirements for lighting found in Code of Federal Regulations (CFR) 49 Part 571.108. However, this does not mean that “anything goes,” and navigating the lighting requirements to determine what may be possible can be very involved and include multiple layers of federal, state and local requirements to review. Federal requirements Along with an understanding of the basic lighting required for a particular vehicle, there is an overriding provision from NHTSA that must be taken into account when considering the addition, modification or combination of any lighting beyond the requirements/provisions of FMVSS 108. S6.2.1 states that “[n]o additional lamp, reflective device, or other motor vehicle equipment is permitted to be installed that impairs the effectiveness of lighting equipment required by this standard.” This has been reinforced in situations to which NHTSA has provided interpretations in relation to strobe lights. In a letter to Richard F. Anderson, dated May 20, 1987, NHTSA states_ “[s]upplemental stroboscopic lamps are not covered by the standard, but as original equipment is nevertheless subject to several restrictions. A lamp that is not covered by Standard No. 108 is permissible if it does not impair the effectiveness of lighting equipment required by the standard.” Similarly, in a letter to Col. W. Gerald Massengill from July 3, 2001, the following excerpt is found_ “Standard No. 108 also prohibits the installation of ‘other motor vehicle equipment . . . that impairs the effectiveness of lighting equipment required by this standard’ (S5.1.3). Strobe lights are ‘other motor vehicle equipment’ within the meaning of this phrase. We read the term ‘installation’ to include use of the other vehicle equipment.” So, even though there may be no specific requirements for strobes from NHTSA, as a final-stage manufacturer or alterer, any such lighting your customer is requesting you to install on a new motor vehicle must not prevent any of the standard lighting from meeting their respective requirements. Determining just what “impairs the effectiveness” of required lighting can be difficult to judge as a manufacturer, but looking at the basic characteristics of lighting requirements can help lend perspective. Lamps have required colors, intensity levels (some minimum and maximum) and visibility throughout a range of angles, as well as required positions on the vehicle. When considering the addition of strobes (or any other lighting or equipment), look at the required lighting in the vicinity of where the strobes are proposed to be located. If it appears the strobe lamp might interfere with these characteristics for any of the required lamps/reflectors, take a closer look at the specific requirements of FMVSS 108 for the standard lighting that may be affected by the addition of the strobe. Some common examples from NHTSA’s interpretation responses that involve strobes or other non-required lighting involve situations where the lights are placed too closely to required lamps, which can mask the visibility and intensity of required lighting. Other common examples of impairing required lamps involve new lighting products that have been proposed to NHTSA that would flash/strobe standard lamp functions, such as stop lamps, which are required to be “steady burning” (see Sidebar below). From a Federal Motor Carrier Safety Administration (FMCSA) perspective, which applies to commercial motor vehicles (see Sidebar below), there are special provisions for flashing warning lights that are contained in CFR 49 Part 393.25(e). These requirements specifically acknowledge “flashing warning lamps on tow trucks and commercial motor vehicles transporting oversized loads; and warning lamps on emergency and service vehicles authorized by State or local authorities” (see Sidebar below). Since FMCSA requirements apply to the motor carrier entity operating a commercial motor vehicle, these requirements should be reviewed with the customer. It is important to note, though, that these FMCSA provisions do not replace a final-stage manufacturer’s or alterer’s compliance responsibilities with FMVSS 108. State and local requirements In addition to considering the affect strobes or other supplemental lighting may have on federal lighting requirements, state and/or local regulations that cover strobe lighting should also be consulted, including any applicable intrastate motor carrier requirements. Similar to FMCSA regulations, state or local requirements often apply to the “use” of such lighting on motor vehicles, so the vehicle owner/operator would normally be responsible for any infractions. Since strobe lighting is typically used on emergency or other non-public vehicles, state and local governments can have provisions for the vehicle applications that may be equipped with such lighting, including any specific color or other lamp characteristics. While it may seem inconsistent, NHTSA does not prohibit end-users from making modifications to their own vehicles after the first retail sale. But this does not extend to other businesses upstream of the end-user for vehicle manufacturing, distribution or repair. This is to allow police departments and other such entities to customize their own vehicles, including lighting, where federal law (49 U.S.C. 30122) otherwise prohibits manufacturers, dealers, distributors and motor vehicle repair businesses from making inoperative safety equipment installed in accordance with the FMVSS. To simplify your research in considering strobe or other non-standard vehicle lighting, first consult the manufacturer of the lighting products being considered to discuss the application with them and request any documentation you may need for your files. To review federal-level requirements of FMVSS 108, login to access NTEA's Interactive Lighting Guide. State and local requirements, including intrastate motor carrier requirements, should be consulted by contacting the local authorities where the vehicle will be used and/or accessing state and municipal websites. Sidebar From NHTSA response letter dated April 2, 1996 to Randy I. McClanahan “This is in response to your letter of February 14, 1996, on the subject ‘Deceleration Rate Signal Generator to Control the Operation of the Center High Mounted Brake Light of Vehicles.’ Citing paragraph S5.5.10(a) of Motor Vehicle Safety Standard No. 108 which requires hazard warning signal lamps to be wired to flash, you believe that ‘the center high mounted brake light’, when controlled by our Brake Alert deceleration rate signal generator, is in fact a `hazard signal lamp’. In your opinion, ‘the installation of our Brake Alert does not alter the factory-installed center high mounted brake light fixture or the bulb(s) therein’, and, therefore ‘not in violation of any Federal Regulations.’ I am sorry to have to tell you that your Brake Alert device is not permitted under Federal regulations. The hazard warning signal lamps covered in S5.5.10(a) refer to a vehicle’s four turn signal lamps flashing simultaneously. Brake Alert, by causing the center high-mounted stop lamp to flash, would not change the center lamp into a ‘hazard warning lamp’ within the meaning of Standard No. 108. When activated by Brake Alert the center lamp would simply be a flashing stop lamp. Under S5.5.10(d) of Standard No. 108, stop lamps must be steady burning. This means that Brake Alert could not be installed as original equipment on a vehicle. With respect to the aftermarket, Federal law prohibits modifications by a manufacturer, distributor, dealer, or motor vehicle repair business that ‘make inoperative’ Federally-required equipment, such as the center stop lamp. We regard causing the center lamp to flash as the equivalent of making it inoperative because it will be operating in a way that is not permitted for new vehicle equipment under Standard No. 108. Federal law, however, does not prohibit the vehicle’s owner from adding Brake Alert if (s)he is capable of doing so. Even if installed by the vehicle owner, the legality of Brake Alert would be determinable under the laws of the states where it is operated.” Definition of CMV Commercial motor vehicle means any self-propelled or towed motor vehicle used on a highway in interstate commerce to transport passengers or property when the vehicle— (1) Has a gross vehicle weight rating or gross combination weight rating, or gross vehicle weight or gross combination weight, of 4,536 kg (10,001 pounds) or more, whichever is greater; or (2) Is designed or used to transport more than 8 passengers (including the driver) for compensation; or (3) Is designed or used to transport more than 15 passengers, including the driver, and is not used to transport passengers for compensation; or (4) Is used in transporting material found by the Secretary of Transportation to be hazardous under 49 U.S.C. 5103 and transported in a quantity requiring placarding under regulations prescribed by the Secretary under 49 CFR, subtitle B, chapter I, subchapter C. CFR 49 Part 393.25(e) § 393.25 Requirements for lamps other than head lamps. e) Lamps to be steady-burning. All exterior lamps (both required lamps and any additional lamps) shall be steady-burning with the exception of turn signal lamps; hazard warning signal lamps; school bus warning lamps; amber warning lamps or flashing warning lamps on tow trucks and commercial motor vehicles transporting oversized loads; and warning lamps on emergency and service vehicles authorized by State or local authorities. Lamps combined into the same shell or housing with a turn signal are not required to be steady burning while the turn signal is in use. Amber warning lamps must meet SAE J845—Optical Warning Devices for Authorized Emergency, Maintenance and Service Vehicles, May 1997. Amber flashing warning lamps must meet SAE J595—Directional Flashing Optical Warning Devices for Authorized Emergency, Maintenance and Service Vehicles, January 2005. Amber gaseous discharge warning lamps must meet SAE J1318 Gaseous Discharge Warning Lamp for Authorized Emergency, Maintenance, and Service Vehicles, May 1998. (See §393.7(b) for information on the incorporation by reference and availability of these documents.) e-CFR Access the e-CFR for the latest editions of FMVSS 108, FMCSA and other Federal Standards.

Are there requirements for strobe, beacon and other forms of auxiliary lighting?

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