Interpretation ID: 7026

Mr. Masashi Maekawa Director, Technical Division Ichikoh Industries, Ltd. 80 Itado, Isehara City Kanagawa, 259-11, Japan

Dear Mr. Maekawa:

This responds to your letter of February 21, 1992, asking for a clarification of our letter of December 18, 1991.

In that letter we discussed "a combination tail/stop lamp that would be mounted on the deck lid ('Lamp B') immediately adjacent to a combination tail\stop lamp that is mounted on the vehicle body ('Lamp A')". You informed us that each lamp complied with the requirement for effective projected luminous lens area, but that neither complied with photometric requirements. You asked whether Ichikoh could consider the two adjacent lamps as one lamp for purposes of measuring photometrics. We replied that it was not possible to consider the two lamps as one, and that we regarded the lamp that was on the vehicle body as the one that should be designed to conform to Standard No. 108.

You have asked whether this advice is consistent with an interpretation given Mazda on June 28, 1985, with respect to a similar design. That letter informed Mazda that compliance of the design would be judged with the vehicle in its normal driving position, thereby implicitly agreeing that the two lamps could be considered one for photometric purposes.

The difference in the interpretations originated in the way each manufacturer described its design. Ichikoh referred to its design as two adjacent lamps. Mazda described its configuration as a (single) lamp constructed so that a portion of it is fixed to the body and a portion on the decklid. Our review of the two designs shows that they are essentially similar, and that the Mazda design comprises, in fact, two adjacent lamps. As it was not our intent to change the earlier interpretation, we confirm that the June l985 interpretation remains valid, and that the December 1991 letter is overruled to the extent that it is inconsistent with it.

Sincerely,

Paul Jackson Rice Chief Counsel

ref:l08 d:4/10/92