Interpretation ID: aiam2352
Commander
Engineering Section
Department of California Highway Patrol
P.O. Box 898
Sacramento
CA 95804;
Dear Mr. Heath: This is in reply to your letter of June 22, 1976, asking fo interpretations of Motor Vehicle Safety Standards Nos. 108 and 205.; Paragraph S4.3.1 of Standard No. 108 requires, as you noted, that lamp and reflective devices be securely mounted on a rigid part of the vehicle. You asked 'whether or not flexible mount clearance and sidemarker lamps should be permitted for use on motor vehicles.' Your question appears directed towards replacement equipment. The answer is that California may regulate mounts for replacement lighting equipment in the manner it deems appropriate. S4.3.1 applies to the mounting of lighting equipment on new motor vehicles, and does not establish a specification for replacement equipment mounts. The replacement clearance and sidemarker lamps themselves are, of course, subject to Standard No. 108.; You also asked whether there was a provision in Standard No. 205 *Glazing Materials*, that would exempt 'Item 3' [AS 3] glazing (to be used for glass partitions and rear side windows of van-type vehicles) from the requirements of ANS Z26 Tests Nos. 1 and 18.; The answer to your question is no. Paragraph S5.1.1 of Standard No. 20 specifies that glazing materials for use in motor vehicles shall conform to the requirements of ANS Z26. The ANS Z26 specifications require 'Item 3' glazing materials to comply with Test No. 1, 'Light Stability,' and Test No. 18, 'Abrasion Resistance,' regardless of where the 'Item 3' glazing is to be used in the vehicle. Thus, there is no provision by which manufacturers of such glazing may be exempted from the test requirements.; Sincerely, Frank A. Berndt, Acting Chief Counsel