ID: nht88-1.81

TYPE: INTERPRETATION-NHTSA

DATE: 03/28/88

FROM: DON O. HORNING -- P. E. INDUSTRIAL TESTING LABORATORIES

TO: C-MORE-LITE, JERRY'S SERVICE

TITLE: TEST REPORT NO: 92606

ATTACHMT: ATTACHED TO LETTER DATED 08/19/88 TO DOUGLAS H BOSCO, FROM ERIKA Z JONES, REDBOOK A32 (2) STANDARD 108 LETTER DATED 06/16/88, TO ERIKA Z. JONES, FROM DOUGLAS H. BOSCO; LETTER DATED 08/03/87 TO DOUGLAS H. BOSCO FROM ERIKA Z JONES; LETTER DATED 0 6/09/88 TO JERRY K YOST FROM L. FROLLIN; 1988 LETTER TO ERIKA Z. JONES FROM JERRY SERVICE

TEXT: Enclosed is the photometric data taken on the Halogen H4651 Single Filament Sealed Beam Headlamp and the Halogen H4656 Dual Filament Headlamp.

The two headlamps were mounted on a standard text fixture placed on the goniometer and aimed per specification SAE J579, Dec 84. Candlepower readings were taken at the appropriate settings with both filaments energized on the H4656 headlamp and with the single filament energized on the H4651 headlamp.

These readings were combined to simulate the operation of the C-More-Lite Headlight relay which activates both filaments on the 2-filament headlamp as well as the single filament to effectively provide both low beam and high beam illumination when the hi gh beam is switched on.

The accompanying table of photometric results at 100 ft were made with the aim established per SAE J579, Dec 84, Section 3.4 and the voltage at 12.8 volts. As indicated at the bottom of the table, the maximums could not be combined, as they did not coin cide as to location. Adjusting either lamp to the location of the other maximum did not produce a combined maximum in excess of the permissible maximum of 75,000 cd.

No tests were run utilizing the C-More-Lite relay in the circuit. tests run only simulate the effect of its operation.

As a part of this report a copy of SAE J579, Dec 84, is included for substantiation of test points and maximum and minimum cd. There is also included a diagram of the measurement points combining both upper and lower beams.

It should be noted that this laboratory takes no position relative to the C-More Relay as regards its utilization.

Description of Headlamps used: ITL TEST NUMBER 92606

1. Lamp Halogen H4651 - 4x6 1/2 inch sealed beam headlamp Westinghouse Headlamps by Philips (Assembled in Mexico) High Beam for 4 head light system Replaces 4651, HP4651 2 lugs - 12 volts Marked - 1A1 Sealed Beam, Halogen, U.S.A. DOT.

2. Lamp Halogen H4656 - 4x6 1/2 inch sealed beam headlamp Westinghouse Headlamps by Philips (Assembled in Mexico) Low Beam for 4 headlamp system Replaces 4656, HP4656 3 lugs - 12 volts Marked - 2A1 Sealed Beam, Halogen, U.S.A. DOT.

[TABLE OF PHOTOMETRIC TESTS H4656 AND H4651 SEAL BEAM HEADLAMPS, ITL TEST NO 92606, OMITTED]

[SAE J579 STANDARD OMITTED]

LOWER BEAM & UPPER BEAM (CHART OMITTED)

ID: nht88-2.81

TYPE: INTERPRETATION-NHTSA

DATE: 08/01/88 EST

FROM: ERIKA Z. JONES -- CHIEF COUNSEL, NHTSA

TO: ROBERT G. YORKS -- VICE PRESIDENT AND GENERAL MANAGER, AUTOMOTIVE BUSINESS GROUP, TRUCK-LITTLE CO.

TITLE: NONE

ATTACHMT: MEMO DATED 5-24-88, TO KATHLEEN DEMETER, FROM ROBERT G. YORKS, 25220; MEMO UNDATED, TO ROBERT G. YORKS, FROM KATHLEEN DEMETER

TEXT: We have received your letter of May 24, 1988, withdrawing your request for confidential treatment of your letter of March 31 concerning the legality of a new safety lighting device. This letter also responds to your inquiry of July 14.

The device is described as a "combination center high-mounted stop lamp and cargo lamp". The functions are optically separate. The cargo lamp can illuminate the cargo box on pick-up trucks, while on vans and utility vehicles it serves as a "utility lig ht". The device is intended to be used as either original or aftermarket equipment.

The Federal motor vehicle safety standard on vehicle lighting is Standard No. 108. As you know, the center high-mounted stop lamp is required only for passenger cars. Further, there is no requirement that a center lamp intended for other types of motor vehicles meet the passenger car lamp requirements (for example, those requirements would prohibit combining the center lamp with the cargo lamp). As neither function of your device is required on lighting equipment for vehicles other than passenger car s, Standard No. 108 permits the installation of your device as original equipment provided that it does not impair the effectiveness of the lighting equipment that the standard does require. Whether impairment exists is initially a determination of the manufacturer of the vehicle who certifies compliance with Standard No. 108. However, the issue of impairment is ultimately subject to a determination by this agency. Types of impairment that can exist include functional interference with the wiring of o ther lamps, creation of ambiguous or confusing signals to such a degree that it may obscure the message of lamps and reflectors required by Standard No. 108, and reduction of photometrics below the minimum levels specified.

As an item of aftermarket lighting equipment, it is subject to a restriction of the National Traffic and Motor Vehicle Safety Act that its installation by a manufacturer, dealer, distributor, or motor vehicle repair business must not render inoperative i n whole or in part any device or element of design installed in accordance with a Federal motor

vehicle safety standard. We construe this prohibition strictly and equate it with impairment. If performance is "impaired," it can be viewed as "inoperative" with respect to achieving the purpose for which it has been installed.

Assuming that installation of an aftermarket device is not restricted by the Act, it nevertheless remains subject to the laws of a State in which the vehicle is registered and driven. We are not conversant with State laws on combination rear lamps, but you may wish to consult the American Association of Motor Vehicle Administrators, 4600 Wilson Boulevard, Arlington, Va. 22203, for an opinion.

I hope that this answers your questions.

ID: nht68-1.39

DATE: 02/20/68

FROM: H. S. BEAGLE -- ELECTRICAL TESTING LABORATORIES, INC.

TO: EDWIN L. SLAGLE -- NATIONAL HIGHWAY SAFETY BUREAU FEDERAL HIGHWAY ADMINISTRATION DEPARTMENT OF TRANSPORTATION

COPYEE: J. R. SCHAEFFER -- ETL; A. R. CHICK -- ETL

TITLE: MOTOR VEHICLE SAFETY STANDARD NO. 205 -GLAZING MATERIALS

REF.1: ELECTRICALLY HEATED SAFETY GLASS FOR DEFOGGING

REF.2: TEST PROCEDURE PER USA STANDARD 226.1-1966

ATTACHMT: LETTER DATED 2/21/68 FROM EDWIN L. SLAGLE OF D.O.T. NATIONAL HIGHWAY SAFETY BUREAU TO H. S. BEAGLE OF ELECTRICAL TESTING LABORATORIES INC.

TEXT: The above subject reference No. 2 provides, in part, that safety glazing material be tested for regular (parallel) luminous transmittance (method unspecified), which value shall be not less than 70 per cent both before and after irradiation (ultraviolet are exposure). The word "parallel" means that the light beam used in making this measurement should be essentially collimated. This condition may be obtained by using a light source sufficiently distant from the test specimen that the rays are essentially parallel.

Our photometric laboratory has been performing this test satisfactorily for many years, using the apparatus shown in the attached photographs numbered 1 through 4, as follows:

Photo #1 - A general view, no glass in place, showing diaphragm plate and source of collimated beam above. Light source, positioned 48 inches above photo cell and shielded, is an incandescent monoplane tungsten-filament lamp calibrated for operation at the specified color temperature of 2854 degrees Kelvin.

#2 - Close up of diaphragm plate with 1-1/4-inch opening, positioned 3/4 inch above the color corrected photovoltaic cell. Cell is visible through diaphragm opening.

#3 - Set-up with glass specimen in place. Glass specimen shown has electrically conductive lines on one surface.

#4 - Close up of glass specimen on diaphragm plate.

In performing this measurement the test specimen is moved laterally across the diaphragm (aperture) to find and record the minimum transmittance value.

2

It is our belief that this test method is as suitable for evaluating the luminous transmittance of electrically heated safety glass as it is for the same glass not so treated. As a matter of fact, it has been so employed in the past with respect to imported glass of the electrically heated type.

However, to avoid possible future problems concerning the acceptability of our test method, we are submitting this matter for your consideration at this time. The urgency of it is related to the long loud time with respect to production of electrically heated safety glass to provide for defogging of rear windows in motor vehicles.

We therefore respectfully ask for your written approval of the test method, as herein described, as being acceptable for purposes of evaluating the luminous transmittance of electrically heated safety glass for compliance in this regard, with the requirements of MVSS No. 205.

The earliest possible response to this request would be most sincerely appreciated.

Sincerely yours,

Enclosure: photographs

ID: nht93-2.4

DATE: 03/03/93

FROM: BARRY FRELRICE -- ASSOCIATE ADMINISTRATOR FOR RULEMAKING, NHTSA

TO: RON MARION -- SALES ENGINEER, THOMAS BUILT BUSES, INO.

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 12-4-92 FROM RON MARION TO BARRY FELRICE (OCC 8073)

TEXT: This responds to your letter asking whether there has been any consideration given to excluding "non-route-type" school buses from Standard No. 131's requirement that school buses be equipped with a stop signal arm. You stated that, as a manufacturer of school bus bodies, you are getting numerous questions regarding the installation of stop arms on school buses not used on route service. According to your letter, a number of schools across the U.S. purchase school buses, paint them a color other than yellow, and use them exclusively for athletic trips. You stated that these buses pick up at the school and travel to another school to unload, and do not make stops for loading or unloading along the way and in no way attempt to control traffic. You stated that the purchasers of these school buses are concerned about paying for stop arms which are never used.

As you know, Federal Motor Vehicle Safety Standard No. 131, School Bus Pedestrian Safety Devices, is a new Federal motor vehicle safety standard which requires all new school buses to be equipped with a stop signal arm. The purpose of the requirement is to reduce deaths and injuries by minimizing the likelihood of vehicles passing a stopped school bus and striking pedestrians in the vicinity of the bus.

To answer your specific question, this agency has not considered whether "non-route-type" school buses should be excluded from Standard No. 131's requirement for a stop signal arm. I note that this issue was not raised in the comments on our notice of proposed rulemaking.

We do appreciate the concern of a purchaser about paying for safety equipment that he or she believes will never be used. However, the limited information provided in your letter does not provide a basis for concluding that we should consider changing the standard.

We do not know how many school buses are used exclusively or primarily for "non-route-type" service, although we assume the number is small. Further, it would appear that there would be occasion to use signal arms for some school buses used for such service. For example, these safety devices might be used while loading and unloading students when the school bus is parked on a school driveway or a road near a school, if the school bus is used to transport students to activities at locations other than schools, or if the school bus is sometimes used as a replacement for out-of-service regular route school buses. T also note that, assuming that there is occasion to use stop signal arms or some school buses which are primarily used for non-route service, it is not clear how the agency would distinguish, for purposes of a regulation, which school buses should be excluded from the requirement for stop arms.

I hope this information is helpful.

ID: nht95-3.77

TYPE: INTERPRETATION-NHTSA

DATE: August 4, 1995

FROM: John Womack -- Acting Chief Counsel, NHTSA

TO: Jim Burgess -- Engineering Manager, Independent Mobility Systems, Inc.

TITLE: NONE

ATTACHMT: ATTACHED TO 5/18/95 LETTER FROM JIM BURGESS TO WALTER MYERS (OCC 10931)

TEXT: Dear Mr. Burgess:

This responds to your letter of May 18, 1995 to this office and your telephone conversations with Walter Myers of my staff on June 14 and 27, 1995, concerning an exclusion in Federal Motor Vehicle Safety Standard (FMVSS) No. 206, Door locks and door rete ntion components. The standard excludes from its requirements doors equipped with wheelchair lifts and either a visual or audible alarm system.

You state that your company converts minivans into wheelchair accessible vehicles by lowering the floor and adding a wheelchair ramp to the right rear side sliding door area, with an audible and/or visual alarm. The issue you raise is whether FMVSS No. 206's exclusion of wheelchair-equipped doors also excludes a ramp-equipped door. The answer is no.

FMVSS No. 206 requires that side doors leading directly into a compartment containing one or more seating positions must conform to the standard. However, paragraph S4 of the standard states:

Side doors equipped with wheelchair lifts and which are linked to an alarm system consisting of either a flashing visual signal located in the driver's compartment or an alarm audible to the driver which is activated when the door is open, need not confo rm to this standard.

FMVSS No. 206 was amended to add the wheelchair lift exception by final rule dated March 27, 1985 (50 FR 12029, copy enclosed). The agency's rationale was that when not in use, wheelchair lifts are stowed in a vertical position parallel to and in close proximity to the interior surface of the vehicle door, thus providing a barrier to occupant ejection if the door opened while the vehicle was in motion or in the event of a crash. The alarm requirement was intended to alert the driver to a door that was open on a vehicle that was in motion.

While the information you provided us showed that your wheelchair ramp is also stowed in a vertical position parallel to and in close proximity to the door and that you install audible and/or visual alarms for the driver, wheelchair lifts and wheelchair ramps are distinctly different components. Although they serve the same purpose and are similarly configured when in the stowed position, this agency cannot by interpretation say that "lift" includes "ramp." In order to amend the standard to exclude whe elchair ramps as well as lifts, rulemaking action would be required. You may petition this agency to do rulemaking, under 49 CFR Part 552 (copy enclosed). This agency will entertain your petition and decide whether a rulemaking proceeding is appropriat e.

I hope this information is helpful to you. Should you have any further questions or need any additional information, please feel free to contact Mr. Myers at this address or at (202) 366-2992.

ID: nht73-1.39

DATE: 06/19/73

FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: Bendix Automotive Aftermarket

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of May 30, 1973 and confirms the telephone conversation with Mr. Vinson of my staff on June 14, 1973.

The amendments to Motor Vehicle Safety Standard No. 116 published on May 17, 1973 modified container labelling requirements only for silicone-based brake fluid and hydraulic system mineral oil (paragraph S5.2.2.3) and did not affect the requirements for conventional DOT 3 and DOT 4 fluids (paragraph S5.2.2.2) as you assumed. Therefore you appear to have no problem, and it is not necessary to consider your letter as a petition for reconsideration.

Sincerely,

Bendix

Automotive Aftermarket

May 30, 1973

Department of Transportation

Attention: Lawrence R. Schneider, Chief Counsel

Reference: Phone conversation with Mr. Taylor Vincent on 5/14/73

Dear Mr. Schneider:

The revision to the FMVSS #116 Standard, as published May 17, 1973, has an effective date for label changes of July 1, 1973, but does not specifically authorize the sellers of Brake Fluid to exhaust existing container stock.

The label changes are minor, as follows:

Existing Safety Warnings:

1. FOLLOW VEHICLE MANUFACTURER'S RECOMMENDATIONS WHEN ADDING BRAKE FLUID.

2. KEEP BRAKE FLUID CLEAN AND DRY. Contamination with dirt, water, petroleum products or other materials may result in brake failure or costly repairs.

3. STORE BRAKE FLUID ONLY IN ITS ORIGINAL CONTAINER. KEEP CONTAINER CLEAN AND TIGHTLY CLOSED TO PREVENT ABSORPTION OF MOISTURE.

4. CAUTION: DO NOT REFILL CONTAINER, AND DO NOT USE FOR OTHER LIQUIDS.

* New Safety Warnings:

1. FOLLOW VEHICLE MANUFACTURER'S RECOMMENDATIONS WHEN ADDING BRAKE FLUID.

2. KEEP BRAKE FLUID CLEAN. Contamination with dirt or other materials may result in brake failure or costly repairs.

3. CAUTION: STORE BRAKE FLUID ONLY IN ITS ORIGINAL CONTAINER. KEEP CONTAINER CLEAN AND TIGHTLY CLOSED. DO NOT REFILL CONTAINER OR USE OTHER LIQUIDS.

* We have corrected the labeling as to the use of upper and lower case letters per the instructions of Mr. Taylor Vincent.

The current safety warning label requirements are not inadequate for the conventional Brake Fluids. Bendix labeling for DOT 3 Brake Fluid conforms to the existing standard for safety warnings.

This letter is a request for permission to exhaust container stock purchased prior to the July 1, 1973, effective date. Existing Bendix container stock is in the form of lithographed containers both filled and unfilled. A minimum of 60 - 90 days is required to modify lithography plates. If permission is not granted, this letter is to be considered a petition to amend the Docket No. 71-13, Notice 4, published May 17, 1973. Please amend this docket to give the conventional Brake Fluid sellers the right to exhaust stock purchased prior to the July 1, 1973, effective date.

Very truly yours,

Cam Brame --

Quality Assurance Analyst

cc: M. J. Stepanek; B. Stubbs; R. Hasnerl; J. Howard

ID: GF006472

Mr. Jim Haigh
Vice President
Transpec Worldwide
7205 Sterling Ponds Ct.
Sterling Heights, MI 48312




Dear Mr. Haigh:

This responds to your e-mail regarding installation of certain auxiliary lighting on school buses. Specifically, you ask whether installing a "Driver Alert Device" on school buses, which you state has been mandated by the State of Alabama, conflicts with Federal Motor Vehicle Safety Standard (FMVSS) No. 108, Lamps, reflective devices and associated equipment.

Your e-mail and your web site (www.transpecworldwide.com/products/driver_alert.htm) explain that the "Driver Alert Device" is an LED message board mounted on the school bus emergency door that is wired to flash the word "Caution" when the school bus is backing up. The device is also wired into the eight-lamp school bus warning lamp system. When the amber lamps of the system are activated, the LED sign alternately flashes "Caution-Stopping". When the red lamps of the system are activated, the sign flashes "Stop" or "Do not Pass".

First, S5.5.10 of FMVSS No. 108 generally requires that all lamps, including auxiliary lighting, must be steady burning, unless otherwise specifically permitted. Your message board does not fall under any exception enumerated in S5.5.10.

Second, S5.1.3 of FMVSS No. 108 prohibits additional lighting devices that impair the effectiveness of lamps required by FMVSS No. 108. The agency interprets the standard as generally prohibiting electronic message boards because they have the potential of impairing the effectiveness of required lighting (see August 4, 1997 letter to Mr. Alan Robinson).

However, with respect to school buses equipped with flashing electronic message boards, we do not prohibit them because we believe that under certain local conditions, an electronic message board could enhance the safety of school bus passengers. That is, we defer to the States with respect to the narrow issue of prescribing or prohibiting electronic message boards on school buses.

We caution that this interpretation is limited to electronic message boards on school buses. For example, the agency recently explained that our standards would prohibit a flashing red lamp located on the roof of a school bus, because it had the potential of impairing the effectiveness of the required lighting (see 5/22/03 letter to J. Adam Krugh IV). Further, electronic message boards must be located far enough away from the required lighting so as to minimize any potential impairment.

If you need further assistance, please contact George Feygin of my staff at this address or at (202) 366-2992.

Sincerely,

Stephen P. Wood
Acting Chief Counsel

2 Enclosures

NCC-112:Gfeygin:mar:11/2/05:62992:OCC 006472
Cc: NCC-110 Subj/Chron, Docket Std. 108
S:\INTERP\108\GF006472.doc

ID: 8838

Mr. Ron Marion
Sales Engineer
Thomas Built Buses, Inc.
P.O. Box 2450
1408 Courtesy Road
High Point, N.C. 27261

Dear Mr. Marion:

This responds to your inquiry about the applicability of Standard No. 131, School Bus Pedestrian Safety Devices, to school buses you wish to sell to a customer in the United States Virgin Islands. You stated that these buses will be built as right hand drive vehicles with the entrance door located on the left side, since vehicles are driven on the left side of the road in this jurisdiction. You asked whether you can install, on the right side of the bus, the stop signal arm that is required by FMVSS 131. The answer is yes.

The National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1381, "Safety Act") requires new school buses sold in this country and in the U.S. Virgin Islands to comply with all applicable Federal school bus safety standards. (See, 15 U.S.C. 1391(8) for reference to the Virgin Islands.) Standard No. 131 requires school buses to be equipped with a stop signal arm "on the left side of the bus." (S5.4) The purpose of this standard is "to reduce deaths and injuries by minimizing the likelihood of vehicles passing a stopped school bus and striking pedestrians in the vicinity of the school bus." (S2)

When NHTSA specified that the stop arm must be placed on "the left side of the bus," the agency meant the driver's side. Comments to the notice of proposed rulemaking (NPRM) and preamble of NHTSA's final rule all assumed that the left side of the bus meant the driver's side. (56 FR 20363, 20367). For example, while endorsing the proposed requirement for the stop arm, several commenters stated that an arm is needed near the driver's window. Moreover, S5.4.1(b) states that, for locating the arm, "the top edge of the stop signal arm is parallel to and not more than 6 inches from a horizontal plane tangent to the lower edge of the frame of the passenger window immediately behind the driver's window." (Emphasis added). This provision indicates that the agency assumed that the "left" side is the driver's side. Further, a stop arm would not be needed on the non-traffic side of the vehicle.

Since the left side is not the driver's side for the school buses in question, the agency's general assumption was incorrect. In light of your letter, we will issue a technical amendment of Standard 131 so that S5.4 will require the stop signal arm on the driver's side of the bus. Until the amendment is issued, we will not take enforcement action regarding a manufacturer's locating a right hand drive school bus with a stop signal arm on the bus's driver's side.

I hope this information is helpful. If you have any questions about NHTSA's safety standards, please feel free to contact Marvin Shaw at this address or by telephone at (202) 366-2992. Sincerely,

John Womack Acting Chief Counsel

ref:131 d:8/l6/93

ID: nht70-1.43

DATE: 02/25/70

FROM: AUTHOR UNAVAILABLE; F. C. Turner; NHTSA

TO: FWD Corporation

TITLE: FMVSS INTERPRETATION

TEXT: RE: PETITION FOR RULEMAKING

This is in reply to your letter of October 16, 1969, requesting an exception from Paragraph S3.1 of Federal Motor Vehicle Safety Standard No. 205 ("Glazing Materials - Passenger Cars, Multipurpose Passenger Vehicles, Motorcycles, Trucks and Buses"), to allow the use of Lemen and Plexiglas in certain specified locations in twenty-one (21) fire fighting vehicles to be delivered to the city of New York.

You state the purpose of your request is to provide better protection for occupants of these fire fighting vehicles from objects thrown at them when, for example, the vehicles are enroute to a fire. Further, you state the use of these materials would eliminate replacing safety glass, which can be broken when hit by small objects. Because you are requesting a change in an existing standard your letter has been treated as a petition for rulemaking to amend Standard No. 205, pursuant to the provisions of 49 CFR @@ 353.31, 353.33. For the reasons stated below, your petition is denied.

It is not completely clear from your letter and the enclosed drawing where the interior or canopy partitions in which you wish to use Lexen and Plexiglas are located. Standard No. 205 presently permits the use of rigid plastics in interior partitions of fire fighting vehicles if these materials meet the requirements for plastics designated AS4 and AS5 (the latter can only be used when not requisite for driving visibility) in American Standards Association Test Z26.1-1966, July 15, 1966. We understand that Plexiglas meets these requirements and may therefore be used in this location. We also understand, however, that Lexen does not, failing specifically to meet certain chemical and abrasion resistance requirements applicable to AS4 and AS5 rigid plastics under the Standard. If our understanding regarding Lexen is correct, we believe its failure to meet these minimum requirements renders its unsuitable for use in areas of motor vehicles where a possible loss of transparency may affect the safe operation of the vehicle.

With reference to glazing in side and door windows of fire fighting vehicles, Standard No. 205 allows the use of glazing specified AS1, AS2, and AS10 in ASA Test-226.1-1966 and also allows the use of AS11 and AS3 glazing at levels not requisite for driving visibility. This glazing may be either laminated, tempered, or bullet resistant safety glass meeting the applicable requirements. Plastics meeting AS4 and AS5 requirements, while appropriate for certain locations such as partitions, are not considered appropriate for use in side and door windows as they do not possess chemical and abrasion resistance qualities necessary for exterior glazing and which the types of safety glass specified above possess. The occupant protection which you desire can be provided by using AS10 (and AS11 where appropriate) bullet resistant glass which contains both structural advantages over normally used safety glazing and satisfactory chemical and abrasion resistance for use in side and door windows.

ID: nht75-2.46

DATE: 06/09/75

FROM: AUTHOR UNAVAILABLE; J. C. Schultz; NHTSA

TO: Wesbar Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of May 13, 1975, requesting an interpretation of paragraph S4.4.1 of Motor Vehicle Safety Standard No. 108 as it applies to a described lamp design.

In pertinent part, S4.4.1 states that "no clearance lamp may be combined optically with any taillamp." The lamp design that interests you has separate compartments for the taillamp and for the clearance lamp. You are concerned that at a distance it will be difficult to distinguish the two lamps, and you feel that this violates the spirit of S4.4.1.

We have no objection to the design of this lamp. Since the clearance lamp and taillamp are in separate compartments and not optically combined, and since Standard No. 108 does not specify a minimum separation distance between the two lamps, the lamp design does not violate S4.4.1.

SINCERELY,

(Graphics omitted) See illustration on original

May 13, 1975

Richard B. Dyson, Active Chief Counsel U.S. Department of Transportation National Highway Traffic Safety Administration

Wesbar Corporation is a manufacturer of lights, primarily used on boat trallers and utility trallers. We have received from a number of our customers an inquiry as to the possibility of making a tall light similar to the attached sketch, which would serve then as a tall light, stop light, turn signal, reflex reflector, and clearance light.

We have taken the position that a light of this type would not meet the spirit of DOT 108, paragraph S 4.4.1, which states, "Two or more lamps, reflective devices, or items of associated equipment may be combined if the requirements for each lamp, reflective device, and item of associated equipment are met, except that no clearance lamp may be combined optically with any tall lamp or identification lamp."

A light of the design we indicate on the enclosed drawing would include a separate compartment for the tall, stop and turn light and a separate compartment for the clearance lamp. However, at a distance of 30 or 40 feet to the rear of the vehicle, it would be very difficult to make a distinction between the tall light and the clearance lamp, except possibly by doing some design work on having a different configuration to the lens on the clearance lamp.

We do not wish to be in the position of second guessing your department's interpretation of S 4.4.1 and would therefore appreciate your comments and interpretation of that section. On receipt of same, we will send a copy of this interpretation to the manufacturers who have made these inquires of us.

Your early attention in this matter will be very much appreciated.

WESBAR CORPORATION

Bernard R. Weber Executive Vice President

SINGLE HOUSING WITH SEPARATE COMPARTMENTS FOR EACH LIGHT

TAIL, STOP & TURN SIGNAL LIGHT

CLEARANCE LIGHT

CLASS "A" REFLEX REFLECTOR

1/8" APPROX. BETWEEN ALL LENSES

(Graphics omitted)

(Graphics omitted)

(Graphics omitted)

(Graphics omitted)