Interpretation ID: aiam3947
Consultant
Hyundai Motor Company
7314 Nineteen Mile Road
Sterling Heights
MI 48074;
Dear Mr. Park: This is in reply to your letter of May 3, 1985, asking for a interpretation of the center high-mounted stoplamp provisions of Motor Vehicle Safety Standard No. 108.; You stated that the Hyundai lamp is 'obscured slightly by the rea window wiper arm' but that 'the effective projective luminous lens area exceeds 4.5 square inches'. You asked whether the wiper arm is considered an obstruction to the lamp.; The agency answered a similar question from Mazda in its response t petitions for reconsideration of the stoplamp requirements published on May 17, 1984 (copy enclosed). NHTSA advised that compliance of the lamp would be judged with a rear wiping system in the design off position, and that photometric conformance would be judged thereby. The lamp must be positioned in such a way that it will comply when tested at any of the photometric test points specified in the standard with the wiper system in the design off position.; I hope that this answers your question. Sincerely, Jeffrey R. Miller, Chief Counsel