Interpretation ID: aiam2090
Staff Safety
Nissan Motor Co.
Ltd.
P.O. Box 1606
Englewood Cliffs
NJ 07632;
Dear Mr. Iinuma: This is in reply to your letter of September 8, 1975, to Mr. Bernd requesting an interpretation of the visibility requirements specified in paragraph S4.3.1.1 of Federal Motor Vehicle Safety Standard No. 108.; Specifically, you ask whether a front turn signal lamp which i partially obscured by the radiator grille as shown on a drawing that you enclosed would meet the specified visibility requirements, if . . .; >>>'1. The lamp met the photometric requirements under the state o being equipped on the vehicle.; 2. We could easily observe through all the photometric test angles tha the lamp was activated.'<<<; If condition 1 above is met, the lamp would appear to comply with th visibility requirements of paragraph S4.3.1.1.; For condition 2 above, SAE Standard J588d, incorporated by reference i Standard No. 108, specifies in part that signals from lamps mounted on the left and right sides of the vehicle shall be visible through a horizontal angle of 45 degrees to the left and right respectively. To be considered visible, the lamp must provide an unobstructed projected illuminated area of outer lens surface, excluding that portion of the lens that may serve as a reflex reflector, at least 2 square inches in extent, measured at 45 degrees to the longitudinal axis of the vehicle. If your design meets the specified requirements, the lamp would also be in compliance with the requirements of paragraph S4.3.1.1.; As you were informed in a meeting with Messrs. Leysath and Vinson o this agency on September 8, 1975, it is not necessary that the entire lamp as partially obscured comply with Standard No. 108. If either the upper or lower portion of the lamp meets the photometric and visibility requirements, that is sufficient for conformance. If certification is based upon the lower portion alone, however, the center of the lower portion must be mounted not less than 15 inches above the pavement.; Yours truly, Richard B. Dyson, Assistant Chief Counsel