Originally Posted By: mrsilv04
My first email message with them was not successful. They played it dumb, and pointed me to the FMVSS statutes.
My response was a question that was succinct and to the point, that requires a yes or no answer. We'll see what they respond with.
You're doing the right thing by holding them accountable. It's usually a sure sign that they don't know what they're doing when they have "DOT certified!" and such on their website; it shows a real lack of understanding of the system...the DOT doesn't certify anything.
Kisan's website has no such claims, however. I think they
know that what they're selling is not permitted by the federal regulations, and so they've gone to no effort to blow smoke up anyone's tail by putting nonsense claims like "DOT certified" on their packaging. Critically, though, they also don't tell you that what they're selling is not legal. Some of their products are 100% road legal (or at least appear to be), such as the headlamp modulator. But some of their products are not legal (such as the stoplamp modulator). It's interesting that they point to the FMVSS statues (probably in a very general sense, so as to cause you to assume they know what they're doing). The very CFR they reference would send them up the creek if any enforcement agency actually took them to task on it.
As with ANY lighting modification, whether it's something like this or a DIY headlamp relay, one must be very prudent to do a quality job installing it and checking on the quality of the product in the first place. A quick look at Kisan's FAQ page (
here) demonstrates how important getting good grounds and good wiring connections. Because the LAST thing you want to do is to make a change that worsens the durability of your lighting system.
Here's something I dug up last night:
http://www.calcoast-itl.com/assets/nhtsa-interpretations-2004-review.pdf
It's an NHTSA interpretation document. The first entry (docket #16928) disallows the State of Tennessee from using "oscillating motorcycle stop lamps". Essentially, they are saying, "Tennessee, you say you are allowing them, but they are still illegal."
Further down, docket #17078 says, "Ruled that deceleration activated flashing brake lamps violated FMVSS 108 regulations. FMVSS 108 S5.5.10 requires that a stop lamp be steady burning. NHTSA specifies that this is necessary to maintain uniformity of signals to insure recognition by the general public."
Docket # 19574 says, "FMVSS 108 mandates that stop lamps be steady burning when activated. Strobe stop lamps would not be permissible."
There's really a lot of consistent information from the regulators on steady burning stop lamps.