2019 F3 illegal in the US?

[Nuke]

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.

 

[SpyderF3]

Interesting

 

[ARtraveler]

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.

opcorn:

 

[Easy Rider]

I'll also be filing a complaint with the DOT.

Make that the NTSB or NHTSA.......or both.

 

[billybovine]

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. :yikes:

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.

 

[Nuke]

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. :yikes:

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.

 

[Nuke]

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.

 

[LeftCoast]

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!

 

[Nuke]

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.

 

[billybovine]

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.

 

[LeftCoast]

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.

 

[Batmobil-F3]

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.

 

[Entropy]

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

 

[Pirate looks at --]

…..or you could just ryde the motorcycle!:banghead:

 

[Fatcycledaddy]

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.

 

[Lawdog]

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.

 

[Jackhartjr]

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?

 

[Entropy]

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

 

[Lawdog]

Thank goodness that got worked out.

 

[Rattlebars]

TricLED has stated that their A-arm signal lights won't work on 2019's (yet).