Interpretation ID: aiam4332
Staff Engineer
Society of Automotive Engineers
Inc.
3001 West Big Beaver
Suite 602
Troy
MI 48084;
Dear Mr. Krueger: This is in reply to your letter of February 10, 1987, asking th National Highway Traffic Safety Administration (NHTSA) to define the term 'optically combined' as used in paragraph S4.4 of Federal Motor Vehicle Safety Standard No. 108. Presently, the SAE is circulating for comment its own proposed definition of the term, to be incorporated into SAE J387 *Terminology -Motor Vehicle Lighting*.; For Many years paragraph S4.4 (your referenced S4.4.1 which wa renumbered recently) has contained a prohibition against optically combining a clearance lamp with a taillamp or an identification lamp. NHTSA has provided written interpretations to those who have asked whether specific designs are 'optically combined' within the meaning of paragraph S4.4, but the agency has not added a definition to paragraph S3, the definition section of the standard. If a definition is to be provided, it must be incorporated into the standard, and the agency is unable to do that without first formally proposing the definition and offering the public an opportunity to comment upon it. I can say, however, that the SAE's proposed definition is not inconsistent with the interpretations of the agency.; These interpretations are available in the NHTSA docket room (Roo 5109, 400 Seventh St., S.W., Washington, D.C.) for your reference should you or other SAE staff or committee members wish to examine them.; Sincerely, Erika Z. Jones, Chief Counsel