Interpretation ID: nht90-2.65

TYPE: INTERPRETATION-NHTSA

DATE: 05/31/90

FROM: STEPHEN P. WOOD -- NHTSA ACTING CHIEF COUNSEL

TO: SUICHI WATANABE -- GENERAL MANAGER AUTOMOTIVE LIGHTING ENGINEERING CONTROL DEPARTMENT STANLEY ELECTRIC CO., LTD.

TITLE: NONE

ATTACHMT: LETTER DATED 03/19/90 FROM SHUICHI WATANABE TO ERIKA Z. JONES -- NHTSA; OCC 4549

TEXT: This is in reply to your letter of March 19, 1990, asking whether a new combination rear lamp is permitted under Motor Vehicle Safety Standard No. 108.

The lamp consists of three compartments. In its normal operating mode, when the taillamp and/or stop lamp are activated, all three compartments show a red light. Your question arises with respect to three different operating modes. The first occurs whe n the turn signal is activated; the red light in one of the compartments is replaced by an amber flashing one. The second occurs when the backup lamp is activated; the red light in another of the compartments is replaced by a white steady-burning one. The third occurs when both the backup lamp and turn signal are activated; in this event, the combination lamp would present an amber flashing light, a red steady-burning one, and a white steady-burning one. You have informed us that "the requirement of photometric and lighted area for each lamp function comply to FMVSS No. 108 and related comply with requirements for one and three compartment lamps when operating with one or three compartments (we assume that they would also meet the requirements for t wo compartment lamps).

The lamp appears to be intended to fulfill the requirements of Standard No. 108 for turn signal, stop, tail, and backup lamps. Thus, your question appears to be whether Standard No. 108 requires separate lamps or compartments dedicated to a specific pur pose, or whether your multiple purpose lamp is acceptable.

Standard No. 108 does not prohibit a combination of the functions that any chamber of your lamp provides. When a specific function is activated, the lamp will perform that particular function in a manner that appears to meet the minimum standard establi shed by Standard No. 108. Assuming that the CIE color definitions for white, amber, and red are met by the backup, turn, and stop/tail functions, the lamp appears to be permissible under Standard No. 108.

Sincerely,