Technical and Legal Clarifications

As pointed out in TLC #103B and #104B … our Single, all Amber 360° FMVSS #108 Photometric Compliant, Tongue Mounted, “Two Way (side pointing) WingTip® Combo Side Marker Light” takes advantage of the “Optical Combination” allowance written into FMVSS #108 … which can simultaneously project a 90° “Test Pattern” (covering from 45° Forward to 45° Rearward*) of Amber light to both Left and Right sides; thus compliantly and conspicuously lighting up both sides of the Trailer Tongue as FMVSS #108 requires for avoiding Intersection, and “T Bone” type Crashes that could come from either the Driver’s or Passenger’s side. *If a full 45° is needed – which depends on other Side Marker positions

Realize that FMVSS #108 … for many years has allowed “Optical Combinations” except for what’s outlined below:

Section S5.4 Equipment Combinations. Two or more lamps, reflective devices, or items of associated equipment may be combined if the requirements for each lamp, reflective device, and item of associated equipment are met, with the following exceptions:

(a) No high-mounted stop lamp shall be combined with any other lamp or reflective device,

other than with a cargo lamp.

(b) No high-mounted stop lamp shall be combined optically, as defined by SAE Information

Report J387 Terminology—Motor Vehicle Lighting NOV87, with any cargo Lamp.

Report J387 Terminology—Motor Vehicle Lighting NOV87, with any taillamp.

We certainly don’t agree with NHTSA’s (a) and (b) restrictions put on CHMSLs (Center, High Mounted, Stop Lamps). Taking into account common sense, real life observations, and the fact that “Conspicuity” for “Presence “ and “Intentions” are supposed to be the prime objectives of FMVSS #108 to meet … it’s apparent to anyone of average reasoning ability that there is nothing that would confuse nearby traffic if NHTSA was, to at least, allow (not mandate) the Optical and Physical Combining of a Center High Mounded Stop Lamp (CHMSL) with either (or both) of the three I.D. Lights and/or with Center High Mounted Augment Turn Signals*. Further, NHTSA should be encouraging, not discouraging, that I.D. lights be mounted at close to ≈average Traffic Eye Height … not 14 feet off the pavement. See our “Request for Legal Interpretations” on this subject.

*Centered High Mounted Augment Turn Signals were allowed by SAE J186 since 1970 and for 20+ years, were unchallenged by NHTSA as

to being a possible source of misguidance or confusion to following or adjoining lane traffic when combined with a CHMSL.

Using this rationale, our 2nd Petition* to NHTSA … asking to allow these beneficial Optical and Physical Combinations … is soon to be sent in*. If our Petition is granted, NHTSA will be asking for comments from interested parties during the standard “Federal Register” Commenting Process … keep in touch to “comment on” and/or to follow the results of this Petition.

*NHTSA denied our 1st Petition

By imagining the 3 I.D. “Running Lights” being “Optically Combined” with an augment Center High Mounted Stop Light (CHMSL) as well as a pair of augment Center High Mounted Turn Signals …we ask, “what can be possibly wrong with a 3 I.D. light bar center mounted at average traffic eye level that also completely lights up when the Brakes or Emergency Signals are applied and also serves as a pair of “Center Mounted” Turn and Lane Change augment indicators allowing more conspicuous and safer lane changing.

Take into account the NHTSA conclusion that their early Taxi Cab tests proved, following drivers most often try to look through the middle of the vehicle in front of them – thus the great decrease in Rear End Crashes and this “center watching” is the reason Center High Mounted Augment Turn Signals will save crashes too!

Regardless, know that if a CHMSL is not mandated*, there is no NHTSA restriction against Optically and Physically Combining this CHMSL with a mandated “I.D. Light” and a pair of “Augment Center, High Mounted Turn Signals”. The only objection NHTSA can put forth is that they won’t allow a mandated 3 I.D. light to be mounted at average Eye Level … which is absurd … see our latest “Interpretation Requests” on this subject.

*Whereas, CHMSLs are not currently mandated by FMVSS #108 for Trailers, RVs, Motor Homes and Big Rigs?

Also, realize that “Optically (and Physically) Combined”*, Side Pointing and Rear and Front Pointing, “Side Marker/Clearance Light” Combinations are FMVSS #108 compliant, as long as all the FMVSS #108 Photometrics and the “Mounting Angles” are compliant … plus all the other Physical testing requirements of FMVSS #108 are also met.

Have you ever noticed a 180° Seeable Red Light mounted 45° to both vehicle axis’s and placed at the rear corner of a Big Rig Trailer or on Over 80” Flatbed Truck? When a 180° Photometric Compliant small light is used in this kind of a 45° tilted “Optical Combination”, it simultaneously informs Cross Traffic and nearby Pedestrians that this Vehicle, indeed exists, and is passing in front of them, as well as simultaneously, truly indicates the “Widest Part” and “Extreme/Overall” Width to following and passing and lane changing traffic. All this “conspicuity” is provided while using just one filament of light on each rear corner of Big Vehicles. Also, this kind of “Optical Combination” means fewer Lights; therefore, saves extra costs and saves energy to boot!

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