Interpretation ID: nht91-7.22

DATE: November 27, 1991

FROM: Masashi Maekawa -- Director, Technical Division, Ichikoh Industries, Ltd.

TO: Paul Jackson Rice -- Chief Counsel, NHTSA

TITLE: Re L03/04

ATTACHMT: Attached to letter dated 12-18-91 from Paul Jackson Rice to Masashi Maekawa (A38; Std. 108)

TEXT:

Enclosed please find our written inquiring concerning the interpretation of photometric output requirements for Tail/stop lamps on passenger cars.

ATTACHMENT

Dear Mr. P.J. Rice,

This letter is a question for the interpretation of photometer output requirements for tail/stop lamps on passenger cars.

We would like to know your opinion toward regarding photometer requirements.

We know the lamp like the following drawing is treated as two separate lamps: one lamp is mounted on the fixed quarter panel and duplicate lamp is mounted on the trunk lid.

Each lamp complies with the effective projected luminous areas requirements, but doesn't comply with the photometric requirement as shown below:

Effective projected Photometric requirement luminous requirement

Lamp A Comply does not comply Lamp B Comply does not comply

In this case, is it possible to apply the combination of lamps (Lamps A & B), as prescribed in S 5.1.1.6 of FMVSS No.108 to the photometric requirement of the stop lamp?

If yes, 1. Is it also possible to apply this provision to Tail lamp? 2. Which photometric requirements, 1 lighted section or 2 lighted sections, will apply?

Drawing of Tail/Stop Lamps A and B in relation to the quarter panel side and trunk lid side.

(Drawing omitted)