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  1. #1
    Active Member Nuke's Avatar
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    Default 2019 F3 illegal in the US?

    As some of you may be aware, the 2019 redesign had the subtle but detrimental change to bring the turn signals OUT of the mirror and incorporate them into the DRLs in the fender. Not sure why this was done, but OK. HOWEVER! I have discovered a severe safety flaw that is actually against DOT regulations that should have prevented their sale in the US. According to DOT regulation 571.108s5.5.11(a), "If optically combined with a turn signal lamp, is automatically deactivated as a DRL when the turn signal lamp or hazard warning lamp is activated, and automatically reactivated as a DRL when the turn signal lamp or hazard warning lamp is deactivated." But this is not the case. When the turn signals are activated, the DRL remains lit, making the signal very difficult to see in certain light conditions and creating a dangerous condition for the rider.

    I contacted BRP directly concerning this issue and they seemed mildly interested at best, responding to my concern by telling me I need to talk to the dealer to see if there is a "fix" for this (even though I explained I purchased the bike a week ago and it was already updated), and that they would review my concern. They also told me that the dealer has some special direct line to technical support that regular customers cannot access. I'll be contacting the dealer tomorrow morning to see what they can come up with.

    I'll also be filing a complaint with the DOT. I'm willing to bet that this will be the only way to force Can Am's hand in fixing this issue, which should be VERY easy to fix since everything is on CAN BUS these days. They just need to flash the ECM to turn off the DRL when the signal is flashing. EZPZ. But that will take money and effort. I hope that anyone with a 2019 is also concerned about this and will contact their dealer to express their concerns to Can Am directly before someone gets hurt. It's already harder to see a biker than a car, and this is making it worse.
    2019 F3 Limited , Phoenix Orange Metallic

  2. #2
    Active Member SpyderF3's Avatar
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    Interesting

  3. #3
    Very Active Member ARtraveler's Avatar
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    Any action may be a bit premature at this time. First, I would be making sure that the information about the alleged safety hazard is correct.


    Currently Owned: 2019 F3 Limited, 2020 F3 Limited: SOLD BOTH LIMITEDS in October of 2023.

    Previously : 2008 GS-SM5 (silver), 2009 RS-SE5 (red), 2010 RT-S Premier Editon #474 (black) 2011 RT A&C SE5 (magnesium) 2014 RTS-SE6 (yellow)

    MY FINAL TALLY: 7 Spyders, 15 years, 205,500 miles

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  4. #4
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    Quote Originally Posted by Nuke View Post
    I'll also be filing a complaint with the DOT.
    Make that the NTSB or NHTSA.......or both.

  5. #5
    Very Active Member billybovine's Avatar
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    I spent a couple years referencing FMVSS 108 and the Canadian version CMVSS 108. When working for a automotive lighting manufacturer. I did not think I would be brushing up on it now.

    You left out a very important part of the regulation that you quoted. That was the first paragraph of this subsection. It covers the scope and definition of DRL covered in this subsection.

    S5.5.11(a) Any pair of lamps on the
    front of a passenger car, multipurpose
    passenger vehicle, truck, or bus,
    whether or not required by this standard, other than parking lamps or fog
    lamps, may be wired to be automatically activated, as determined by the
    manufacturer of the vehicle, in a
    steady burning state as daytime running lamps (DRLs) and to be automatically deactivated when the headlamp
    control is in any ‘‘on’’ position, and as
    otherwise determined by the manufacturer of the vehicle, provided that each
    such lamp:

    Please take notice that motorcycle is not not covered under this subsection.

    2018 F3 LIMITED

  6. #6
    Active Member Nuke's Avatar
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    Quote Originally Posted by billybovine View Post
    I spent a couple years referencing FMVSS 108 and the Canadian version CMVSS 108. When working for a automotive lighting manufacturer. I did not think I would be brushing up on it now.

    You left out a very important part of the regulation that you quoted. That was the first paragraph of this subsection. It covers the scope and definition of DRL covered in this subsection.

    S5.5.11(a) Any pair of lamps on the
    front of a passenger car, multipurpose
    passenger vehicle, truck, or bus,
    whether or not required by this standard, other than parking lamps or fog
    lamps, may be wired to be automatically activated, as determined by the
    manufacturer of the vehicle, in a
    steady burning state as daytime running lamps (DRLs) and to be automatically deactivated when the headlamp
    control is in any ‘‘on’’ position, and as
    otherwise determined by the manufacturer of the vehicle, provided that each
    such lamp:

    Please take notice that motorcycle is not not covered under this subsection.
    I don't think that it's excluded from the spirit of the law which should cover the use of DRL on any motor vehicle designed for use on public roads.
    2019 F3 Limited , Phoenix Orange Metallic

  7. #7
    Active Member Nuke's Avatar
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    Quote Originally Posted by Easy Rider View Post
    Make that the NTSB or NHTSA.......or both.
    If I'm not mistaken, the NHTSA is part of DOT... regardless, I've filed my complaint with the NHTSA. They are going to investigate.
    2019 F3 Limited , Phoenix Orange Metallic

  8. #8
    Customer Support LeftCoast's Avatar
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    A “technical miss” is always possible but I’m sure BRP has a decent sized legal dept that rendered some sort of judgment on this BUT it could get interesting anyway.

    Keep us updated!
    2015 Pearl White RTL
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    2015 RTL , Yes Pearl White

  9. #9
    Active Member Nuke's Avatar
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    Quote Originally Posted by Jackhartjr View Post
    Not trying to be a jerk Nuke, however, if you have to say, "I don't think that it's covered by the spirit of the law, etc", then you don't know!
    Please find out before posting.
    And, "spirit of the law", really! Lol
    Starting with "not trying to be a jerk" is literally saying "I'm gonna be a jerk here... sooo...." Anyway, yes, the spirit of the law. When the laws were written, DRLs were already required for all motorcycles in the US. The DOT regulations only mention other vehicles because they aren't required, so if they are going to be implemented, there had to be a standard. To date, I'm not aware of any other bike that has combined DRLs and turn signals before the '19 F3 so there was no conception of needing to specify motorcycles were included in the DOT standards, that doesn't mean that they should be excluded. There's a clear intent to regulate the operation of combined DRL/indicators for SAFETY. Despite your skepticism, the NHTSA is currently investigating, so we'll see how that shakes out.
    2019 F3 Limited , Phoenix Orange Metallic

  10. #10
    Very Active Member billybovine's Avatar
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    Quote Originally Posted by Nuke View Post
    Starting with "not trying to be a jerk" is literally saying "I'm gonna be a jerk here... sooo...." Anyway, yes, the spirit of the law. When the laws were written, DRLs were already required for all motorcycles in the US. The DOT regulations only mention other vehicles because they aren't required, so if they are going to be implemented, there had to be a standard. To date, I'm not aware of any other bike that has combined DRLs and turn signals before the '19 F3 so there was no conception of needing to specify motorcycles were included in the DOT standards, that doesn't mean that they should be excluded. There's a clear intent to regulate the operation of combined DRL/indicators for SAFETY. Despite your skepticism, the NHTSA is currently investigating, so we'll see how that shakes out.
    My memory is a little foggy but I believe that motorcycles are covered in a separate section. Keep reading. You should eventually find it. Most subsections will state what they cover. If a vehicle type is not mentioned it not covered. If a subsection scope says trucks and buses only. It does not cover passenger vehicles and snowmobiles. The fender lights are not DRLs. Sorry they are just not bright enough. The headlights are the DRLs on a Spyder. That's why they come on when the engine starts. So DRLs on a 2019 F3 are not combined with the turn signal.

    PS If the fender lights are DRLs. DRLs that are not headllights must be mark as such by the letters DRL, on the surface of the lens 3mm high.

    2018 F3 LIMITED

  11. #11
    Customer Support LeftCoast's Avatar
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    Quote Originally Posted by Nuke View Post
    Starting with "not trying to be a jerk" is literally saying "I'm gonna be a jerk here... sooo...." Anyway, yes, the spirit of the law. When the laws were written, DRLs were already required for all motorcycles in the US. The DOT regulations only mention other vehicles because they aren't required, so if they are going to be implemented, there had to be a standard. To date, I'm not aware of any other bike that has combined DRLs and turn signals before the '19 F3 so there was no conception of needing to specify motorcycles were included in the DOT standards, that doesn't mean that they should be excluded. There's a clear intent to regulate the operation of combined DRL/indicators for SAFETY. Despite your skepticism, the NHTSA is currently investigating, so we'll see how that shakes out.
    I guess I did not get that deleted in time. Now that the rebuttal point has been made thanks for moving on everyone.
    2015 Pearl White RTL
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    2015 RTL , Yes Pearl White

  12. #12
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    I don't think the F3 2019 is illegal, because the lights in the fender are not DRL but position lights according to the manual.

  13. #13
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    Quote Originally Posted by billybovine View Post
    My memory is a little foggy but I believe that motorcycles are covered in a separate section. Keep reading. You should eventually find it. Most subsections will state what they cover. If a vehicle type is not mentioned it not covered. If a subsection scope says trucks and buses only. It does not cover passenger vehicles and snowmobiles. The fender lights are not DRLs. Sorry they are just not bright enough. The headlights are the DRLs on a Spyder. That's why they come on when the engine starts. So DRLs on a 2019 F3 are not combined with the turn signal.

    PS If the fender lights are DRLs. DRLs that are not headllights must be mark as such by the letters DRL, on the surface of the lens 3mm high.

    ^^^ This is 110% correct.

    I would, however, advocate fer more effective / visible turnsignals on the 2019 F3L, without resorting to aftermarket tacky (pun intended) stick-on LED strips, etc. For myself, a retrograde to pre-2019 mirror turnsignals is on my bucket list.

    E

  14. #14
    Very Active Member Pirate looks at --'s Avatar
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    …..or you could just ryde the motorcycle!
    White 2013 Spyder RT Limited. BajaRon Swaybar, Custom Dynamic Third Brake Light. Ultimate Custom Black and White seat with driver and passenger back rest. Gloryder Led Wheel lights.Custom Dynamics Led Bright sides, Amber and Red Fender lights, and Saddle Bag Bright sides.

    2016 F3 Limited Intense Red Pearl. Lidlox, BRP Driver Back Rest, BRP Passenger Back Rest,Fog Lights, GPS, Signature Light! Custom Dynamics LED Bright Sides, Amber and Red Fender lights, and Saddle Bag Bright Sides.

  15. #15
    Very Active Member Fatcycledaddy's Avatar
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    Quote Originally Posted by Nuke View Post
    I'll also be filing a complaint with the DOT. I'm willing to bet that this will be the only way to force Can Am's hand in fixing this issue, which should be VERY easy to fix since everything is on CAN BUS these days. They just need to flash the ECM to turn off the DRL when the signal is flashing. EZPZ. But that will take money and effort. I hope that anyone with a 2019 is also concerned about this and will contact their dealer to express their concerns to Can Am directly before someone gets hurt. It's already harder to see a biker than a car, and this is making it worse.
    What ever happened to "if you are unhappy with something don't buy it?"
    Now everyone seams to think that their own personal preferences and ideas or interpretations of something is law, and everyone needs to abide by their own personal version of things.
    If you don't like the lights, change them, if you don't want to do that, take it back.
    Why run to a government agency and cause what could be years of legal battles, (you know that it wont stop with the lights) cause more legal expense to a company which on turn is passed on to the customer. There is a reason cars, trucks cost the ridicules amount they do. Too many government regulations and mandatory things imposed on each and every one.
    But again, this is just my opinion I am sure.
    2020 RT Limited , Petrol Blue

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    Believe me, if there was something wrong with the way the lights are mounted or positioned, NHTSA and/or DOT would have caught it. The bike would not have been allowed to be brought into the country if there was a problem.


    Lawdog, retired police but still doing the job for second retirement.
    2018 Spyder RT Limited
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    Folks, all I was trying to say was please, know what you are talking about.
    I see this all of the time in trucking forums.
    I have to remind folks to read the regulations.
    And if you'll remember, I did put lol at the end of the post.

    Has anyone figured out if the lights in question are illegal?

  18. #18
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    Quote Originally Posted by Jackhartjr View Post

    Has anyone figured out if the lights in question are illegal?
    Figured out =Yes

    Illegal = No

    To coin a highly techincal term used elsewhere on here in lieu of actual knowledge - Position lights are 'Diddly', (or rather, 'Squat')

    Now - perhaps an argument can be forwarded regarding these 'Position' lights and their 'shrouding' / 'masking' effect on the visibility of active signals. Answer - move signals, and/or increase the intensity of same in-situ.

    E
    Last edited by Entropy; 07-03-2019 at 04:24 PM. Reason: spellin'

  19. #19
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    Thank goodness that got worked out.


    Lawdog, retired police but still doing the job for second retirement.
    2018 Spyder RT Limited
    Asphalt grey, chrome, back rest, arm rests, cup holders from canamspyderaccessories.com

  20. #20
    Very Active Member Rattlebars's Avatar
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    TricLED has stated that their A-arm signal lights won't work on 2019's (yet).
    to see my 2016 F3-T and many how to's
    2016 F3-T SE6 Roadster , Extended brake pedal for which I drilled out the brake rod yolk to lower it and added spacers to lift it slightly Black/Grey

  21. #21
    Active Member Don'tPanic's Avatar
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    The fender lights are not DRLs, they are "Position Lights"
    DRLs are in your headlights.

  22. #22
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    Quote Originally Posted by Rattlebars View Post
    TricLED has stated that their A-arm signal lights won't work on 2019's (yet).
    Good thang, too.

    There are much more elegant methods to enhance one's visibility without festooning ye trike with crap and resembling a gaudy, cheap carnival ride..... Jesus Christ ....

    carnival1.JPG

    #TRICyouintoemptyingyerwalletLED

    E

  23. #23
    Very Active Member Rattlebars's Avatar
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    Quote Originally Posted by Entropy View Post
    Good thang, too.

    There are much more elegant methods to enhance one's visibility without festooning ye trike with crap and resembling a gaudy, cheap carnival ride..... Jesus Christ ....

    carnival1.JPG

    #TRICyouintoemptyingyerwalletLED

    E
    I'm glad your not one of those opinionated blokes. Once you've been hit as many times as I have, you might reconsider so don't paint yourself into a corner like that.
    to see my 2016 F3-T and many how to's
    2016 F3-T SE6 Roadster , Extended brake pedal for which I drilled out the brake rod yolk to lower it and added spacers to lift it slightly Black/Grey

  24. #24
    Active Member CA Railwhale's Avatar
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    The fender tip lights/turn signals aren't daytime running lights. The DTLs are the headlights that are on anytime the engine is running. That's why no one is paying any attention to you, your complaint has no basis in fact.

  25. #25
    Customer Support LeftCoast's Avatar
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    Quote Originally Posted by Jackhartjr View Post
    Folks, all I was trying to say was please, know what you are talking about.
    I see this all of the time in trucking forums.
    I have to remind folks to read the regulations.
    And if you'll remember, I did put lol at the end of the post.

    Has anyone figured out if the lights in question are illegal?
    Jack people come here all the time thinking they know what they are talking about, not to intentionally spread bad info. Look at the tire and oil threads EVERYONE thinks they know what they are talking about. The point being if someone is incorrect just give them the correct, or what you believe to be the correct info, rather than tell them to not post if they don't know what they are talking about. lol at the end doesn't make up for the comment at the beginning. Unfortunately text posts lose the intent that you weren't trying to be rude.

    I too want to know what the ruling is when he finds out.
    2015 Pearl White RTL
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    2015 RTL , Yes Pearl White

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