Interpretation ID: aiam3733
Manager
Mazda (North America) Inc.
23777 Greenfield Road - Suite 462
Southfield
MI 48075;
Dear Mr. Nakaya: This is in response to your letter of July 8, 1983 asking for a interpretation of Motor Vehicle Safety Standard No. 108.; Section S4.2 of SAE Standard J588e *Turn Signal Lamps* establishes minimum distance of 4 inches from the optical axis (filament center) of the front turn signal to the inside diameter of the retaining ring of the headlamp providing the lower beam. You believe that it is not necessary to have a retaining ring on a semi-sealed headlamp and you have asked whether you may substitute the edge of the reflector (as shown on your drawing) to measure the dimension covered by S4.2 of J588e.; The point depicted on your drawing appears to be the inner edge of th reflector, rather than the extreme edge, nevertheless, the 'reflector edge' you have indicated is the approximate location of a retaining ring on a fully sealed headlamp, and is therefore acceptable as a measuring point under Standard No. 108.; Sincerely, Frank Berndt, Chief Counsel