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Civilian Headlight and Keyed Ignition Switches for FMTV/LMTV - Looking for Input

106
11
18
Location
Belgrade, Montana
I'm scratching my head as to what's wrong with the military headlight switch. On, off, seems to work fine.
aleigh - nothing necessarily "wrong" with military MVLS, except it is not intuitive for people that aren't as familiar with driving military vehicles and they may inadvertently drive without brake lights or turn signals. Our goal is to improve safety and make FMTV's easier and more intuitive for a larger population.

Our switch kit overrides the default blackout function (improved safety factor as brake lights and turn signals will always work without the need to manipulate a "SVC" switch) and provides a "set it and forget it" light switch that any driver can operate. It also provides dimmer and dome light functionality.

Thanks!
 
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porkysplace

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aleigh - nothing necessarily "wrong" with military MVLS, except, it is illegal (because it disables brake lights and turn signals, in violation of FMVSS Standard 108 )and it is not intuitive for people that aren't as familiar with driving military vehicles. Our goal is to improve safety and make FMTV's easier and more intuitive for a larger population.

Our switch kit overrides the default blackout function (improved safety factor as brake lights and turn signals will always work without the need to manipulate a "SVC" switch) and provides a "set it and forget it" light switch that any driver can operate. It also provides dimmer and dome light functionality.

Thanks!
It may be illegal after you modify the trucks you sell , but it is not illegal to buyers of military trucks that are original.
The military exemption transfers to future owners with the vehicle
.

Posting this kind of misinformation isn't good for the FMV community

According to; Floridia FMV plate rules it may prevent getting a FMV plate


CHAPTER 2005-47
House Bill No. 623
(6) For purposes of this section, “former military vehicle” means a vehi-
cle, including a trailer, regardless of the vehicle’s size, weight, or year of
manufacture, that was manufactured for use in any country’s military forces
and is maintained to represent its military design and markings accurately.

http://laws.flrules.org/2005/47

C



---------------------------------------------------------------------------------------------------------------------
TYPE: Interpretation-NHTSA

DATE: March 16, 1994

FROM: John Womack -- Acting Chief Counsel, NHTSA

TO: John M. Tolliday -- President, Dayman USA Inc. (Bedford, VA)

TITLE: None

ATTACHMT: Attached to letter dated 8/7/89 from Stephen P. Wood to Clifford Anglewicz (Sec 102); Also attached to letter dated 9/2/93 from John M. Tolliday to John Womack (OCC 9063)

TEXT:

We have received your letter of September 2, 1993, with respect to your wish to import "British Army Ferret Armored Cars." The armaments have been removed. You would be selling these vehicles "on the basis they would only be used for off road purposes." You ask whether the vehicles would be exempt from the Federal motor vehicle safety standards. You have enclosed two photos of the machine.

By way of background, I would like to discuss how military vehicles manufactured in the United States are treated under the National Traffic and Motor Vehicle Safety Act, the authority for the Federal motor vehicle safety standards (FMVSS). The first qu estion to be answered is whether any particular vehicle is a "motor vehicle" as defined by the Safety Act, that is to say, whether it is a vehicle that has been manufactured primarily for use on the public roads. If we conclude that a vehicle is manufac tured primarily for on road use, it is a "motor vehicle," notwithstanding the fact that it may be sold "on the basis they would only be used for off road purposes." We see no way in which a seller can bind a purchaser to such use, and, certainly, such a restriction would not be binding on subsequent owners of the vehicle. As for individual vehicle types, to state the obvious, a tracked motor vehicle such as a tank intended for cross-country off-road terrains is not a "motor vehicle." If a vehicle, suc h as a military bus, has been manufactured primarily for on- road use, it is a "motor vehicle." However, NHTSA excuses vehicles from compliance with the FMVSS if they have been manufactured in accordance with contractual specifications of the armed forc es of the United States (49 CFR 571.7(a)). Furthermore, because the Safety Act does not regulate sales of vehicles to owners subsequent to the original one, the U.S. armed forces may sell military vehicles to the public at the end of their useful milita ry life without having to bring them into conformity with the FMVSS (however, because of safety policy considerations they have not done so with respect to M-151 jeeps and HMMV vehicles).

The importation of used military vehicles manufactured abroad is governed differently. Under the Safety Act, any "motor vehicle," whether new or used, that is imported into the United States must be brought into conformity with all FMVSS that applied at the time of its manufacture. The question that must be answered is whether a Ferret, at the time of importation, would be considered a "motor vehicle." In an interpretation concerning an "armored security vehicle" then being used by the U.S. armed for ces, we informed the manufacturer, Verne Corporation on August 7, 1989, that the vehicle would have to conform to the FMVSS if sold for civilian use. I enclose a copy of that interpretation. We believe that this interpretation applies to the Ferret as well, and, therefore, the vehicle is not exempt from the FMVSS. Because of the

overall configuration of the Ferret with its high approach and departure angles and its suitability for use on rough terrain, the FMVSS that would apply are those that must be met by a "multipurpose passenger vehicle."


Assuming you are still interested in importing the Ferret's for resale, the Imported Vehicle Safety Compliance Act requires that the agency determine that the vehicles are capable of conversion to meet the FMVSS, and that the Ferrets be imported by a "re gistered importer." The agency makes determinations upon the basis of a petition by the manufacturer or registered importer (or upon its own volition). A "registered importer" is one whom NHTSA has recognized as capable of converting vehicles to meet t he FMVSS. If you would like further details on eligibility determinations and import procedures, please let us know and we shall be pleased to provide them.




p.s. the letter can be found on the NHTSA website at;

http://isearch.nhtsa.gov/gm/94/nht94-1.78.html
 
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aleigh

Well-known member
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49
48
Location
Phoenix, AZ & Seattle, WA
aleigh - nothing necessarily "wrong" with military MVLS, except, it is illegal (because it disables brake lights and turn signals, in violation of FMVSS Standard 108 )
It's not illegal. The trucks were exempt as manufactured and that transfers to civilian owners.

I don't know what kind of parties you guys are having over in Montana, but I don't let random people drive my 8.25 ton curb weight full air truck without instruction, which includes how to operate a switch designed for 18 year olds...

I fully admit to bias though, I prefer the trucks be original as much as practical. Call it a collector thing, or whatever you like, so I scratch my head like an old grouch at some of these mods. I think you'll find that a common sentiment on this site - and what sets us apart from other expo sites. We're collectors first.
 

porkysplace

Well-known member
Steel Soldiers Supporter
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1,484
113
Location
mid- michigan
It's not illegal. The trucks were exempt as manufactured and that transfers to civilian owners.

I don't know what kind of parties you guys are having over in Montana, but I don't let random people drive my 8.25 ton curb weight full air truck without instruction, which includes how to operate a switch designed for 18 year olds...

I fully admit to bias though, I prefer the trucks be original as much as practical. Call it a collector thing, or whatever you like, so I scratch my head like an old grouch at some of these mods. I think you'll find that a common sentiment on this site - and what sets us apart from other expo sites. We're collectors first.
Claiming they are illegal to uninformed FMV owner's is a good sales pitch .
 
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106
11
18
Location
Belgrade, Montana
porkysplace-

"Claiming they are illegal to uninformed FMV owner's is a good sales pitch" is not a fair statement at all. We are here to service this community, not dupe it.

I started this thread simply to gauge interest from the group, which seems to be positive. One member asked what the purpose of the switch was and I responded, factually. I have built hundreds of custom commercial trucks, buses and emergency vehicles over 25 years and am VERY well versed in Canadian Federal Motor Vehicle Safety Standards (CMVSS) and U.S. Federal Motor Vehicle Safety Standards (FMVSS), from which I made my statement.

The Code of Federal Regulations, Title 49, Transportation, Subtitle B, Regulations Relating to Transportation, Chapter V, Department of Transportation, Part 571, Federal Motor Vehicle Safety Standards, Standard No. 108, which regulates the "legality" of "Lamps, reflective devices, and associated equipment" makes it illegal to have what is in essence, a "kill switch" that disables of otherwise prevents the automatic activation of brake lights or turn signals while driving. You are welcome to familiarize yourself with the standard here if you please.


Here is just some of the applicable language from the Standard::


"Required Lamps and Reflective Devices; Stop Lamps “Must be activated upon application of the service brakes”. Turn Signal Lamps; MUST “Flash when the turn signal flasher is actuated by the turn signal operating unit.

No additional motor vehicle equipment is permitted to be installed that impairs the effectiveness of lighting equipment required by this standard."
(i.e. a "kill switch")



In short, operating a motor vehicle on a public road or highway in the USA or Canada with an MVLS switch, or more specifically their inherent blackout mode, is quite illegal.


Additionally, operating a motor vehicle on a public road or highway in the USA or Canada without a rear illuminated license plate lamp is also illegal (which is why we sell those too!). ;-)


Thank you
 

aleigh

Well-known member
1,040
49
48
Location
Phoenix, AZ & Seattle, WA
As has been pointed out to you, the fmvss does not apply here. You'd be right if it did, but it does not, so quoting the fmvss further does no good. If you want to refute the nhtsa letter, then by all means make your case, but quoting the fmvss over and over is not going to make your case, since we don't think it applies.
 

porkysplace

Well-known member
Steel Soldiers Supporter
9,604
1,484
113
Location
mid- michigan
porkysplace-

"Claiming they are illegal to uninformed FMV owner's is a good sales pitch" is not a fair statement at all. We are here to service this community, not dupe it.

I started this thread simply to gauge interest from the group, which seems to be positive. One member asked what the purpose of the switch was and I responded, factually. I have built hundreds of custom commercial trucks, buses and emergency vehicles over 25 years and am VERY well versed in Canadian Federal Motor Vehicle Safety Standards (CMVSS) and U.S. Federal Motor Vehicle Safety Standards (FMVSS), from which I made my statement.

The Code of Federal Regulations, Title 49, Transportation, Subtitle B, Regulations Relating to Transportation, Chapter V, Department of Transportation, Part 571, Federal Motor Vehicle Safety Standards, Standard No. 108, which regulates the "legality" of "Lamps, reflective devices, and associated equipment" makes it illegal to have what is in essence, a "kill switch" that disables of otherwise prevents the automatic activation of brake lights or turn signals while driving. You are welcome to familiarize yourself with the standard here if you please.


Here is just some of the applicable language from the Standard::


"Required Lamps and Reflective Devices; Stop Lamps “Must be activated upon application of the service brakes”. Turn Signal Lamps; MUST “Flash when the turn signal flasher is actuated by the turn signal operating unit.

No additional motor vehicle equipment is permitted to be installed that impairs the effectiveness of lighting equipment required by this standard."
(i.e. a "kill switch")



In short, operating a motor vehicle on a public road or highway in the USA or Canada with an MVLS switch, or more specifically their inherent blackout mode, is quite illegal.


Additionally, operating a motor vehicle on a public road or highway in the USA or Canada without a rear illuminated license plate lamp is also illegal (which is why we sell those too!). ;-)


Thank you
As I posted the military has a exemption that passes to future owners ( This is clear in the copy of the letter I posted
and has been a key point in title and registering battles in several states) . Here in michigan the courts have ruled no plate light is needed as it didn't come with one.

I agree after you modify them they are no longer exempt as they have been altered . Your blanket statement that the stock headlight switch is illegal is false and misleading and is where some dmv employee decides these shouldn't be on the road.
Read what Wisconsin and Georgia has went through and the result . Your blanket statement is not a postive post for the MV collecting community . Does your switch had benifits to the converting there trucks probably.

This is the FMTV forum not the Vendors forum ( which as of this posting you have never posted in ) , so maybe you need to go back and read the letter posted in post #9 . So as a FACT that when the truck is sold by the military it has the same FMVSS exemptions the military had.

Since this is the FMTV forum and not the Vendors forum , facts and opinions acceptable posts.

Edit; Also many states require inspections and if these were illegal as you claim none of the trucks would pass.
 
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106
11
18
Location
Belgrade, Montana

I've replaced the military switch with a simple switch.
I am considering making the keyed switch work with a relay to the lights so there isn't a switch at all.
What does an electronic dash set-up like that cost your clients?
Nice work! We have discussed offering a replacement instrument panel for A1's but it is quite involved...and we're not really sure if we can offer without a LOT of hands on support.

And...it would cost several thousand dollars so not sure of the market size.

A0's have a mechanical engine so we'd never attempt.

A1R's we may offer a relatively simple plug and play solution, but again not sure of market size because of lack of A1R's.

Will probably survey the forum in early summer to gauge interest.

Thanks!
 
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