The big rewrite
Feb 1, 2008 12:00 PM, BY RICK WEBER
It's in the books. Finally.
After numerous delays, the long-awaited rewrite of Federal Motor Vehicle Safety Standard (FMVSS) 108 appeared in the Federal Register on December 4, listed as the National Highway Traffic Safety Administration's (NHTSA) 49 CFR Parts 564 and 571, and starting with page number 68234.
The final rule amends the standard on lamps, reflective devices, and associated equipment by reorganizing the regulatory text so that it provides a more straightforward and logical presentation of the applicable regulatory requirements, which includes the agency's interpretation of the existing requirements. It also greatly reduces the need to consult relevant third-party standards by including applicable requirements directly into the main body of FMVSS 108 rather than incorporating such provisions by reference. This final rule does not impose any new substantive requirements on manufacturers.
Spanning 207 pages, it might seem rather daunting. But it is pure bliss to Brad Van Riper, senior vice president and chief technology officer for Truck-Lite, chairman of the Society of Automotive Engineers (SAE) lighting committee, and past president of the Transportation Safety Equipment Institute (TSEI).
“It's a significant improvement for the industry,” he says. “The benefits of the rewrite are that many of the requirements are in one section, rather than scattered throughout the document. If you need to know about headlights, you can go to the headlights section. If you need to know about stop lamps, go to the stop lamps section. That order in itself is the biggest overall benefit. With a little bit of effort, you can find all of the performance requirements for the different lighting functions without having to scan through the entire document.
“There was an effort to take the referenced SAE standards and, because some of them are so old they're out of print, integrate the verbiage from them into the standard so the people who haven't been in the industry very long have access to the requirements.
“A few of us in the industry have an intimate knowledge of the FMVSS 108 standard because we use it every day. But for an OEM who might want to release a new model truck or trailer, it's a painstaking effort to understand all the requirements because ultimately the OEMs are responsible for certifying that their vehicles comply with the standard based on equipment location and the functions that are required in the standard. If you don't have that intimate knowledge of knowing right where those rogue additions to the standard are, or if you haven't done the effort — like some OEMs have — of electronically linking the functional requirements together, this reorganized standard will be very useful.”
New features are useful
Van Riper says one of the most useful new features is a cross reference that starts on page 128 of the document.
“It is quite accurate and will be quite useful for people looking for certain things in the document,” he says. “It gives you the opportunity to cross reference the current FMVSS 108 or incorporated document citation against the initially proposed re-write against the final rule. So you have some degree of cross reference between all three of the documents.”
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