ID: 19843.ztv

Mr. Masao Muraoka
Deputy General Manager
Technical Administration ept.
Koito Mfg. Co., Ltd.
Shizuoka Works
500, Kitawaki
Shimizu-Shi, Shizuoka-ken
Japan

Re: Motorcycle Headlamp Photometry

Dear Mr. Muraoka:

This is in reply to your letter of April 6, 1999, pointing out an inconsistency between our letter to Stanley Electric Co. of February 22, 1999, and preamble language to a 1996 amendment of Federal Motor Vehicle Safety Standard No. 108.

The issue is the measurement of photometrics in two-lamp motorcycle headlamp systems: whether the photometric performance of Figure 32 is applied to each headlamp, or to the combined maxima of both headlamps. Our first interpretation on this subject was provided to M. Iwase of your company, who asked us about the measurement of photometrics in a two-lamp motorcycle headlamp system. We informed Mr. Iwase on November 29, 1985, that:

The fact that the combined maximum value of your system exceeds 75,000 candlepower [for upper beam] is permissible as long as the individual lamps themselves do not exceed 75,000 candlepower.

We confirmed this interpretation in the preamble of the 1996 amendment to Standard No. 108 adopting a new photometric standard for motorcycle headlamps (61 FR 45359). There we said that:

When a motorcycle is equipped with a two-lamp headlamp system, there is no summing of test point values in determining compliance. Each headlamp for use on a motorcycle must comply with specified photometrics for a single lamp, and not as a system of two headlamps.

Thus, the maximum values apply to a single headlamp, and not the system of two headlamps as [Koito and Suzuki] appear to believe" (at 45360).

However, our letter of February 22 informed Stanley Electric that "a [motorcycle headlamp] system of the type described in subparagraph (b) of S7.9.6.2 [a two-lamp system] is not intended to have twice the light output of systems described in S7.9.6.2(a) or S7.9.6.2(c)," which you interpret as contrary to our previous interpretations. You ask that we seek public comment if it is our intent to adopt "one photometric performance for each motorcycle."

We appreciate your calling this matter to our attention. We agree that our interpretation is incorrect and withdraw that portion of our letter of February 22 that is inconsistent with prior interpretations. A conflict appears to arise in the context of a motorcycle headlamp system permitted by S7.9.6.2(b), a two-lamp system in which each lamp contains an upper beam light source, or each lamp contains a lower beam light source. This system could produce total beam photometrics of twice the light output of a single beam system (S7.9.6.2(a)or S7.9.6.2(c)). The edges of luminous lens areas of headlamps meeting S7.9.6.2(b) must be no more than 8 inches apart when they are mounted horizontally, and our remarks in our letter of February 22 reflected our concern that this may be an insufficient distance to prevent glare arising from two beams, especially from the lower beam when other drivers are in close proximity. If you intend to produce a two-headlamp system with two full-intensity upper or lower beams, please keep in mind our safety concerns about glare.

We intend to study this question in the coming months as part of a petition from the Japanese Automotive Parts Industry Association, and would appreciate any data you may have on this subject.

Sincerely,
Frank Seales, Jr.
Chief Counsel
ref:108
d.9/29/99

ID: 19844.ztv

Mr. Glenn Panes
921 Todville Road
Seabrook, TX 77586

Dear Mr. Panes:

This is in reply to your e-mail of April 7, 1999.

You are interested in buying an aftermarket combination stop/turn signal lamp which has a clear lens and red and amber bulbs. You ask whether the lamps are legal to use. Apparently your local police do not object, but you are concerned about being stopped somewhere else.

The answer to your question depends on a number of factual issues, as well as the laws of local and state jurisdictions. Therefore, this is not a question we can fully answer for you.

We establish the Federal motor vehicle safety standards that apply to new motor vehicles and vehicle equipment from the time of manufacture until time of first sale. One of these, Federal Motor Vehicle Safety Standard No. 108 Lamps, Reflective Devices and Associated Equipment specifies the lighting equipment a vehicle must have when manufactured, and the performance of this original equipment and the aftermarket equipment intended to replace it. We can tell you how this standard relates to the aftermarket lamp you describe.

Aftermarket replacement equipment is required to comply with Federal new-equipment requirements, and be certified as complying. We are unable to tell whether the combination stop/turn signal lamp you describe complies but would like to make a few comments on it. Under Standard No. 108, a turn signal lamp is permitted to emit amber light. The amber light may be provided by either an amber lens and clear bulb, or an amber bulb and a clear lens. The question, then, is whether the turn signal lamp meets Standard No. 108's photometric specifications.

Standard No. 108 has incorporated by reference the Society of Automotive Engineers (SAE) specifications for amber turn signal lamps.

SAE specifications for stop lamps are also incorporated by reference in Standard No. 108. These specifications require the use of special bulbs for testing purposes. However, SAE has no specifications for red bulbs. Thus, it may not be possible for manufacturers to certify that a lamp meets all applicable Federal motor vehicle safety standards. Nevertheless, if the manufacturer has marked the replacement lamp with a "DOT" symbol (or certified its conformance on its container), you may regard that as its representation that the lamp meets all applicable Federal requirements.

This certification, however, does not mean that the original equipment lamp can be removed and the new, different one substituted without causing a noncompliance with Standard No. 108. The standard requires vehicles to have two red reflex reflectors on their rear, and one on each side at the rear. In many instances, these reflectors are incorporated into red rear combination lamp lenses. Thus, depending on the location of red reflex reflectors on the side and rear of the car, substitution of a white-lensed stop lamp might remove this desirable safety feature.

Even if the lamp were certified as complying, if installation of the lamp you are interested in would result in removal of the only reflex reflectors on the side and/or rear, there would be a violation of Federal law if this work was performed by a manufacturer, distributor, dealer, or motor vehicle repair business, and if the modifier did not add two reflex reflectors to the rear of the car. However, this prohibition does not apply to you, if you, the vehicle's owner, substitutes the lamp. Nevertheless, it is possible that you could be cited somewhere for a violation of local laws if the vehicle lacks rear reflex reflectors. As a general rule, we urge caution in replacing any lighting equipment with novelty items.

Some new motor vehicles may be equipped with original equipment rear combination lamps that have clear lenses, but the red color of the light emanating from these lamps is produced by a clear bulb projecting through a red inner plastic lens. Such lamps do not use red bulbs and are certified as complying.

If you have any further questions, you can contact Taylor Vinson of this Office, either by phone (202-366-5263), or by e-mail (Tvinson@nhtsa.dot.gov).

Sincerely,
Frank Seales, Jr.
Chief Counsel
ref:108
d.6/14/99

ID: 19845.ztv

Mr. P. Binder
Valeo Deutschland
Stuttgarter Strasse 119
74321 Bietigheim-Bissingen
Germany

Dear Herr Binder:

This responds to your fax of April 12, 1999, to Taylor Vinson of this Office, asking for an interpretation of Federal Motor Vehicle Safety Standard No. 108.

On August 2, 1994, we addressed your rear motor vehicle lighting array. Sketch 1 in your new letter depicts that lighting array: a stop lamp, turn signal lamp, taillamp, and reflex reflector mounted on the car body and, immediately adjacent on the tailgate, a backup lamp, fog lamp, taillamp, and reflex reflector. You were concerned with requirements for the taillamp system, and we confirmed your interpretation that the combination of taillamp 1 and taillamp 2 could be used to meet the photometric requirements for two lighted sections.

You now ask whether that interpretation also applies to a new taillamp design (Sketch 2) that will be used to replace the old design (Sketch 1). In this design, the taillamp portion of Sketch 1 lamp array appears to have been replaced with light guides and light-emitting diodes (LEDs). Our interpretation does not apply to your new taillamp design. Because more than two LEDs are used (i.e., more than two light sources), the lamp must meet the photometric requirements for three lighted sections.

The fundamental difference between the old and new systems is that each lighted section of the lamps in Sketch 1 contains a single light source whereas the taillamps in Sketch 2 require more than one light source to achieve compliance with the photometric performance required of a single lighted section. Thus, a lamp using three or more light sources must meet the photometry of a three-compartment lamps.

You asked about additional regulations. We have proposed that lamps with LEDs be designed to conform to photometric requirements based on the dimension of the effective projected luminous lens area for the function being tested (63 FR 34350 at 34356, June 24, 1998). A lamp is regarded as having one lighted section if the maximum horizontal or vertical linear dimension of the effective projected luminous lens area of the lamp is less than 150 mm, two lighted sections if the dimension is 150-300 mm, and three lighted sections if the dimension is greater than 300 mm. We have not yet made a decision concerning a final rule. Some commenters have expressed significant concerns that this proposal is wrong. We are evaluating these comments. In the meantime, you should not design future lamps on the assumption that NHTSA will adopt the proposal.

If you have further questions, please contact Mr. Vinson (FAX 202-366-3820).

Sincerely,
Frank Seales, Jr.
Chief Counsel
ref:108
d.7/7/99

ID: 1984y

Dear:

With respect to the interpretation furnished you on July 21, l989, you have requested the following clarification in your letter of the 28th: that the provisions of paragraph S7.4 of Standard No. l08 that relate to filament usage do not apply to the headlamp system previously described. You have also confirmed that this system is designed to conform to all other requirements of Standard No. l08 "including photometric, special wiring, mechanical aim, environmental and marking requirements.

Paragraph S7.4 describes a variety of headlighting systems which come under the heading of "integral beam systems." The beams in these systems will be produced by "beam contributors" (S7.4(a)(3)), headlamps containing "two light sources" (S7.4(b)), or headlamps containing "a single filament" (S7.4(c)). The arc tubes in the system you describe would appear to be "beam contributors" within the meaning of S7.4, and the filament language of paragraph S7.4 would not apply to this particular type of integral beam headlighting system.

We will honor your continuing request that your name and those of your firm and client be deleted from the copy made publicly available.

Sincerely,

Stephen P. Wood Acting Chief Counsel

ref:l08 d:8/l7/89

ID: 1985-01.1

TYPE: INTERPRETATION-NHTSA

DATE: 01/01/85

FROM: AUTHOR UNAVAILABLE; Jeffrey R. Miller; NHTSA

TO: Masaki Ogura -- Manager, Truck Engineering, MMC Services Inc.

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. Masaki Ogura Manager, Truck Engineering MMC Services Inc. 3000 Town Center, Suite 501 Southfield, Michigan 48075

This responds to your letter concerning Federal Motor Vehicle Safety Standard No. 101, Controls and Displays. According to your letter, your trucks, which have a GVWR of more than 10,000 pounds, have a coolant temperature sensor for overheat warning and also a coolant level sensor for lack of engine coolant to prevent engine overheating. Both sensors are connected to the same telltale lamp, so that either excessive coolant temperature or lack of coolant will illuminate the telltale. Your letter noted that Standard No. 101 specifies an identifying symbol for coolant temperature but not a symbol for coolant level. You asked whether a system displaying the symbol specified by Standard No. 101 for coolant temperature meets the requirements of the standard. As discussed below, while some of Standard No. 101's requirements are applicable to your trucks, the standard's telltale requirements do not apply to trucks with a GVWR of 10,000 pounds or more.

Section 5, Reguirements, states:

Each passenger car, multipurpose passenger vehicle, truck and bus manufactured with any control listed in S5.1 or in column 1 of Table 1, and each passenger car, multipurpose passenger vehicle and truck or bus less than 10,000 pounds GVWR with any display listed in S5.1 or in column 1 of Table 2, shall meet the requirements of this standard for the location, identification, and illumination of such control or display. (Emphasis added.)

Thus, Standard No. 101's requirements for identification of controls are applicable to trucks with a GVWR of 10,000 pounds or more, but the standard's requirements for identification of internal displays are not applicable to such vehicles. Since telltales for coolant temperature are a type of internal display, that requirement of Standard No. 101 is not applicable to the vehicles (more than 10,000 pounds) described by your letter.

Sincerely, Jeffrey R. Miller Chief Counsel

December 24,1984

Mr. Frank Berndt Chief Counsel National Highway Traffic Safety Administration U.S. Department of Transportation 400 Seventh Street, S.W. Washington, D.C. 20590

Subject: Telltale Identifying Symbol for Coolant; FMVSS No. 101 Controls and Displays

Dear Sir:

This is to inquire about the identifying symbol for engine coolant.

1. Our interpretation is as follows:

In Standard No. 101 the telltale identifying symbol for coolant temperature is specified, but a symbol for coolant level is not specified.

2. Telltale for coolant

Our trucks (more than 10,000 pounds GVWR) have a coolant temperature sensor for overheat warning, and also a coolant level sensor for lack of engine coolant to prevent engine overheat.

Both sensors are connected to the same telltale lamp, so that either excessive coolant temperature or lack of coolant will illuminate the telltale for coolant temperature described in FMVSS No. 101 (column 4).

3. Question

Does our system described above conforms to FMVSS No. 101?

Very truly yours,

Masaki Ogura Manager Truck Engineering

MMC SERVICES INC.

ID: 1985-01.10

TYPE: INTERPRETATION-NHTSA

DATE: 01/11/85

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHSTA

TO: Kazutoshi Kasagi -- Chief Inspector, International Trade and Industry Inspection Institute Ministry of International Trade and Industry (Japan)

TITLE: FMVSS INTERPRETATION

TEXT: Mr. Kazutoshi Kasagi Chief Inspector Internationally Agreed Safety Division International Trade & Industry Inspection Institute Ministry of International Trade & Industry Japanese Government 15-1, 6 Chome Ginza Chuo-ku Tokyo, Japan

This is in reply to your letter of November 13, 1984, with respect to interpretations of the motorcycle headlighting requirements of Federal Motor Vehicle Safety Standard No. 108, and SAE J584.

You have asked "whether other lighting systems than referred in S4.1.1.34, such as non-sealed beam head lamp with two bulbs, are acceptable or not." The answer is yes. Non-sealed lamps meeting the requirements of SAE J584 are acceptable, including those with two bulbs, as the "At-Focus Tests" paragraph of J584 is directed to "light source or sources."

Your next question is whether photometric compliance is judged when one light is on or two, including the maximum permissible output of 75,000 cd. The answer to this question depends on the design of the lamp; if it is designed so that both bulbs operate simultaneously, then photometrics including maximum output are determined with both bulbs operating. If the design is such that one bulb produces lower beam and the other the upper beam, then compliance is judged by that method of operation. Should one bulb produce both lower and upper beams and the other bulb perform an unregulated lighting function, then the photometric compliance would be judged with only the bulb used for the regulated function. In this case, however, the unregulated bulb must not interfere with the effectiveness of the headlamp. This also answers your final question about conduct of the out-of-focus test. It is to be conducted according to the design intent of the operation of the headlamp, i.e. the design function of each bulb or bulbs.

You have also asked about the geometrical center of a design when one of two bulbs (both with an upper beam and a lower beam filament apparently) is on. Operation of only one bulb alone would result in an assymetrical lighting display off the vehicle's centerline. This is permitted by S4.1.1.34 of Standard No. 108 for the sealed beam lighting systems specified therein. Therefore, we could not logically disapprove of it for unsealed headlighting systems. However, if only one bulb performed both the lower beam function and the upper beam, and the other bulb performed an unregulated lighting function, then the bulb providing the lower/upper the lower beam function and the upper beam, and the other bulb performed an unregulated lighting function, then the bulb providing the lower/upper beams must be located on the vehicle's vertical centerline.

If you have any further questions, we shall be happy to answer them.

Sincerely,

Frank Berndt Chief Counsel

November 13, 1984

Mr. Frank Berndt, Chief Counsel Office of Vehicle Safety Standards, National Highway Traffic Safety Administration, DOT, 400 Seventh Street, S.W., Washington, D.C. 20590, U.S.A.

Dear Mr. Frank Berndt:

This is to ask you about interpretation and applicability of FMVSS 108 and SAE J584(Motorcycle Headlamp). Before asking questions, I'm pleased to introduce our organization. International Trade and Industry Inspection Institute (ITIII) is an affiliated inspection organization of Ministry of International Trade and Industry, Japanese Government and has three main functions. ITIII itself conducts test and inspections of industrial products under the control of MITI and ITIII administrates private inspection organizations, consumer bodies and manufacturers in terms of inspection and test. ITIII also is involved in the drafting process of inspection standards and inspection method of industrial products. ITIII has been an approved laboratory of lighting equipments by American Association of Motor Vehicle Administrators (AAMVA) and we have regular visits of Mr. Bardel and Mr. Cardarelli from AAMVA. We keep close relations with AAMVA for many years.

Inquiry

FMVSS 108 S4. 1. 1.34 specifies acceptable lighting system of motor cycles. This arises the question of whether other lighting systems than referred in S4.1.1.34, such as non-sealed beam head lamp with two bulbs, are acceptable or not. If it is acceptable, we have three questions to ask you further with regard to SAE J584.

Question 1

Which case should non-sealed beam lamp comply with specified photometric value of SAE J584 either when one bulb is lighted on or two bulbs are on? How should we interpret the requirement of Maximum 75000 cd in each case?

Question 2

Which should be the case of geometrical center when one bulb is on as illustrated below?

"INSERT GRAPHIC"

Question 3

How should we conduct out of focus test of the applicable case asked in question 1?

I hope this contact will be the first step to create good relation with your organization and I appreciate your quick response to our question.

Best regards,

Kazutoshi Kasagi

Chief Inspector, Internationally Agreed Safety Division

ID: 1985-01.11

TYPE: INTERPRETATION-NHTSA

DATE: 01/11/85

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Herbert R. Apuzzo -- Laboratory Supervisor, American Safety Equipment Corporation, Corporate Quality Assurance & Reliability

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. Herbert R. Apuzzo Laboratory Supervisor American Safety Equipment Corporation Corporate Quality Assurance & Reliability 11441 Bradley Avenue Pacomia, CA 91331

This responds to your letter of September 25, 1984, to Mr. William Smith which was forwarded to this office for reply. You asked several questions concerning the requirements of section 5.2(b) of Standard No. 209, Seat Belt Assemblies, which are answered below.

Your first question concerns the conditioning requirements of Procedure D of ASTM D756-78, which is incorporated by reference in Standard No. 209. You pointed out that the agency' s compliance test procedure (document TP-209-01) calls for conditioning for 24 hours, while ASTM D756-78 calls for conditioning for not less than 40 hours. The conditioning requirement incorporated by reference in Standard No. 209 is the correct version and is the method which will be used by the agency. The version of the agency's compliance test procedure you cite was prepared before the June 30, 1983, amendments to Standard No. 208 which adopted ASTM D756-7B. The compliance test procedure will be revised to specify not less than 40 hours of conditioning.

Your second question concerned the requirement of Procedure D that part of the testing be done in a sealed container placed over water in a 176oF recirculating oven. The test calls for maintaining "a humid atmosphere" in the sealed container. You asked what percentage of humidity should be maintained.

You are correct that Procedure D does not specify the specific percentage of humidity. However, section 6.2, Test conditions, of ASTM D756-78 specifies that the tests should be conducted in the Standard Laboratory Atmosphere of 23 +- 2oC and 50 +- 5% relative humidity "unless otherwise specified in the test methods or in this practice." Since Procedure D does not specify a humidity level, the agency will use the humidity of 50 +- % relative humidity specified in section 6.2.

You also asked whether a recirculating chamber can be used to conduct the test. The test equipment specified in the standard is the equipment the agency will use in its compliance tests. Manufacturers are free to use other test equipment as long as they can make a good faith certification that their product complies with the requirements met in the standard.

Your final question concerns another difference between ASTM D756-78 and the compliance test procedure. As explained above, the version of the compliance test procedure you cite was prepared before the June 1983 amendments to the standard and will be updated to cite the requirements adopted in those amendments. You asked for a description of "dessicator" and "uncharged dessicator" referred to in ASTM D756-7B. A dessicator is a closed container that has a drying agent to absorb moisture. An "uncharged dessicator" is a dessicator that does not have a test specimen in it.

In addition, you asked whether you could use an environmental chamber rather than a dessicator. As discussed previously, the test procedures and equipment specified in the standard are the procedures and equipment which the agency will use in its compliance tests. Manufacturers are free to use other test equipment and procedures as long as they can make a good faith certification that their product complies with the requirements set in the standard.

If you have any other questions, please let me know.

Sincerely,

Frank Berndt Chief Counsel September 25, 1984

Mr. William E. Smith Office of Vehicle Safety National Highway Traffic Safety Administration 400 Seventh Street, Southwest Washington, D.C. 20509

Mr. Smith,

American Safety Equipment Corporation, a major manufacturer of Seat Belt Restraint Systems, requires an interpretation of a long-standing but updated ASTM Standard identified in FMVSS-209, paragraph SS.2(b) "Hardware Temperature Resistance".

The Federal registry, under docket 48 FR 30138 (June 30, 1983) amended said paragraph to include updated ASTM D756-78, procedure D, which did not incorporate present standard industry practices.

In this regard, would you please review the following and inform American Safety Equipment of your interpretation.

1. Paragraph S5.2(b) calls for "Conditions prescribed in procedure D of ASTM D756-78" which in turn calls for conditioning at 73.4 +- 3.6 F and 50 +- 5% RH. for not less than 40h, per ASTM Methods D618, while TP-209-01 (page C-1) calls for conditioning for 24 hours. It is our understanding that 24 hours conditioning (as called out in TP-209-01) is "Standard" in the automotive industry, as opposed to the 40 hour conditioning period identified in ASTM D756.

Question: Will both methods satisfy the requirements of FMVSS-209?

2. ASTM D756-78, Procedure D calls for testing "OVER WATER" (at 176o F, in recirculating oven) in sealed container with small capillary "To maintain a humid atmosphere", but does not mention any specific percentage of relative humidity. In general practice, environmental chambers capable of relative humidity from near-zero to 100% are being used to maintain high humidity.

Question: What percentage of humidity can be expected with the "OVER WATER" method, and will recirculating chambers satisfy this requirement?

3. ASTM D756-78, calls for bringing specimens to room temperature in an "Uncharged dessicator which will require 10-30 minutes", then within 2h of exposure over water, expose the specimen for 24h in the oven at 176o F.

TP-209-01 states: "Within two humid of the humid exposure, place the specimens in a DRY HEAT OVEN which has been pre-conditioned to a temperature of 176 = 1.8o F for 24 hours, but does not mention the use of an uncharged dessicator for 10-30 minutes.

Question: Would you please provide us with a description of "Dessicator" and "Uncharged Dessicator" and a determination as to the acceptability of an environmental chamber set at 73.4 +-3.6oF and 50 +- 5% RH to bring specimens to room temperature and then to 176 +- 1.8oF dry heat.

We would appreciate your response (written) at your earliest possible convenience so that American Safety Equipment can maintain the most accurate test conditions possible.

Thank you,

Herbert R. Apuzzo Laboratory Supervisor American Safety Equipment Corporation Corporate Quality Assurance & Reliability 11441 Bradley Avenue Pacoima, CA 91331

HA:dm

cc: F. Neumann T. Israelson

ID: 1985-01.12

TYPE: INTERPRETATION-NHTSA

DATE: 01/15/85

FROM: AUTHOR UNAVAILABLE; Ken Rutland; NHTSA

TO: Docket Section Docket No. 83-12; Notice 2

TITLE: FMVSS INTERPRETATION

TEXT:

U.S. Department of Transportation

Date: Jan. 15, 1985

Subject: INFORMATION: Clarification of Requirements of Final Rule on Harmonization (Docket No. 83-12; Notice 2)

From: Ken Rutland Safety Standards Engineer

To: Docket Section Docket No. 83-12; Notice 2

THRU: Barry Felrice Associate Administrator for Rulemaking

VIA: Frank Berndt Chief Counsel

I received a telephone call from Mr. Kazue Watanabe of the Stanley Electric Company, Tokyo, Japan on December 19, 1984, with a question concerning the November 26, 1984, Final Rule amendment to harmonize FMVSS No. 108 with European standards. With the amendment Published in Notice 2, Mr. Watanabe wanted to know if motorcycle turn signal lamps were supposed to meet the photometric requirements of Table I of SAE J588e or the requirements set forth by Figure 1a and Figure 1b given in Notice 2, after December 26, 1984.

I transmitted the attached message to Mr. Watanabe by telex, on December 27, 1984.

Attachment (w/6 copies)

Interpretations NOA-30 Std. 108 Interpretations Room 5109 Red Book (3)

To: Mr. Kazue Watanabe Stanley Electric Co. Telex # 246-6623 SEC TOKJ

For motorcycle turn signal lamps, FMVSS No. 108 as amended (FR 46386, November 26, 1984), allows motorcycle turn signal lamps to meet one-half of the minimum photometric values at each test point, as specified in SAE J588e, according to S4.1.1.30 and substituting the values in figure 1a and 1b for table 1 of SAE J588e. This requirement is now located in S4.1.1.11 for the 19 individual test points. The new S4.1.1.12 substitutes Figure 1C for the former Figure 1 and establishes the group totals for 5 zonal groups. It is intended that the individual test points with a value of one-half that of Figure 1b be used in determining the group totals for motorcycle turn signal camps. We hope this answers your question.

ID: 1985-01.13

TYPE: INTERPRETATION-NHTSA

DATE: 01/16/85

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Mr. William Shaw

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. William Shaw Sales Manager Shinn Fu Co. of America, Inc. 1004 Andover Park East Seattle Washington 98188

Dear Mr. Shaw:

This in in reply to your letter of December 5, 1984, with respect to the permissibility under Federal regulations of a "Supplemental Eye-Level Rear Stop Light" which provides functions additional to a stop signal.

Federal Motor Vehicle Safety Standard No. 106 Lamps, Reflective Devices and Associated Equipment specifies requirements only for center high-mounted stop lamps as original equipment on passenger cars, and for equipment that replaces original equipment center high mounted stop lamps.

If you offer this device to new car dealers for installation on new cars before their sale, the dealer bears the responsibility for insuring that the car he sells complies with the center high mounted stop lamp requirements for new motor vehicles. On vehicles manufactured before September 1, 1986, equipped with the center lamp, that lamp may flash with the hazard warning lamp, but it cannot be combined with other lighting functions such as turn signals.

However, the device you wish to offer appears intended as an aftermarket device and not intended as original equipment for passenger cars. If this assumption is correct, there is no Federal standard that applies to it, and its legality must be determined according to the law of each State where it will be in use.

We hope that this information has been helpful. Sincerely, Frank Berndt Chief Counsel U. S. Dept of Transportation Dec. 5, 1984 Office of Chief Counsel NHTSA 400 7th St. S.W. Washington, D.C. 20590 Dear Sir,

We're a manufacturer of Supplemental Eye-Level Rear Stop Light and we understand it must meet the requirement of Federal Standard if we want to marketing this product.

Now, our question is: If we design it with multi functions, will it be O.K br D.O.T? That means it is designed with not only the stop light function, but also is designed with the hazard flashing light function for emergency use and with the automatic warning flashing light function if this supplemental light catches the high-beam bright lighting from the rear vehicle which approaches closely behind you in a short, unsafe distance. The designed is patented and is definitely helpful for highway safety.

Please help us by confirming this letter as soon as possible or advising us otherwise. Thank you in advance for your great help. Shinn Fu Co. of America Inc. William Shaw Sales Manager WS/ny Encl.

ID: 1985-01.14

TYPE: INTERPRETATION-NHTSA

DATE: 01/16/85

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Donald W. Vierimaa -- Director of Engineering, Truck Trailer Manufacturers Association

TITLE: FMVSS INTERPRETATION

ATTACHMT: 5/2/69 letter from Charles A. Baker to Reliance Trailer and Truck Company Inc.; 11/10/81 letter from F. Berndt to Truck Trailer Manufacturers Association

TEXT:

Mr. Donald W. Vierimaa Director of Engineering Truck Trailer Manufacturers Association 1020 Princess Street Alexandria, VA 22314

This is in reply to your letter of December 7, 1984 asking our "concurrence that the front clearance lamps on a trailer with a low front end or one designed to be equipped with a tarpaulin...may be mounted at the trailer frame level ( about 50 inches above the ground), to avoid these lamps reflecting into the driver's eyes by way of the side view mirror."

You thoughtfully attached a copy of my letter to you of November 10, 1981 in which I advised you that "the determination of practicability is one that is made by the manufacturer of the trailer", and that "NHTSA will accept a determination that mounting of clearance lamps at the top...is not practicable if such lamps are reflected into the driver's eyes by way of the side view mirror." That remains our view if the configuration of any the side view mirror." That remains our view if the configuration of any trailer is such that location of clearance lamps at or near the top of the trailer results in the reflection of the light into the eyes of the driver of the truck tractor.

Sincerely,

Frank Berndt Chief Counsel Truck Trailer Manufacturers Association ALEXANDRIA, VA. 22314 December 7, 1984 Frank Berndt, Chief Counsel NHTSA, NOA-30 400 Seventh Street, S.W.

Washington, D.C. 20590

SUBJECT: Request for Interpretation of the Height of Front Clearance Lamps on Trailers with Effective Low Front Ends

Dear Mr. Berndt:

We request your concurrence that the front clearance lamps on a trailer with a low front end or one designed to be equipped with a tarpaulin which would necessicate mounting the clearance lamps low may be mounted as the trailer frame level (about 50 inches above the ground), to avoid these lamps reflecting into the driver's eyes by way of the side view mirror.

In your letter of May 2, 1969 to Reliance Trailer and Truck Company, you stated that, "the front clearance lamps should be mounted as high as practicable to clear the bottom edge of the tarp." In your letter of November 10, 1981 to TTMA you stared that with regard to low front bulkheads on platform trailers that, "NHTSA will accept a determination that mounting of clearance lamps at the top or the bulkhead is not practicable if such lamps are reflected into the driver's eyes by way of the side view mirror."

With your concurrence, the sketch in our Recommended Practice No. 9, "Location of Lighting Devices for Trailers", will be revised as shown in the attachment.

Sincerely yours,

Donald W. Vierimaa Director of Engineering Attachments: Interpretations(Letters referenced above) - see 5/2/69 letter to Reliance Trailer and Truck Co., and 11/10/81 letter to Truck Trailer Manufacturers Association RP No. 9 with Drawing - Omitted.

cc: TTMA Engineering Committee