Interpretation ID: 1982-3.11

TYPE: INTERPRETATION-NHTSA

DATE: 10/21/82

FROM: AUTHOR UNAVAILABLE; S. R. Scheiner; NHTSA

TO: Kioto Manufacturing Co., Ltd.

TITLE: FMVSS INTERPRETATION

TEXT:

October 21, 1982

AIR MAIL

M. Iwase, Manager Technical Administration Department Koito Manufacturing Co., Ltd. Shizuoka Works 500 Kitawaki Shimizu-Shi, Shizuoka-Ken JAPAN

Dear Mr. Iwase:

This is in reply to your letter of September 8, 1982, regarding signal flashing on an auxiliary lamp. You asked several questions on your proposed auxiliary lamp which would be installed as original equipment to supplement the lower beam headlamp:

1. Whether this auxiliary lamp would be legally accepted to be flashed for a passing signaling purpose.

2. In case that this auxiliary lamp is designed to comply with the requirements of SAE J583d - Fog Lamps, instead of SAE J582a -Auxiliary Low Beam Lamp: Whether the auxiliary lamp (Fog Lamp) could be legally accepted to be flashed for a passing signal purpose.

The answer to these questions is: No.

Paragraph S4.6 of Federal Motor Vehicle Safety Standard (FMVSS) No. 108, Lamps, Reflective Devices, and Associated Equipment allows turn signal and hazard warning signal lamps to flash but subparagraph (b) states:

"All other lamps shall be steady-burning, except that means may be provided to flash headlamps and side marker lamps for signaling purposes."

We interpret "all other lamps" to include all lamps, required and auxiliary lighting such as the lamp you propose.

In summary we interpret FMVSS No. 108 not to allow the auxiliary lamp you propose to be used as a flashing lamp.

Sincerely,

Stanley R. Scheiner, Acting Chief Crash Avoidance Division Office of Vehicle Safety Standards

NHTSA:OVSS:CAD:Medlin:orb:9/27/82:(JWASE) REWRITTEN:Medlin:orb:9/30/82 RETYPED:orb:10/7/82: REW:Vinson:nbb 10/18/82 Copies to: NRM-01 Chron NRM-11 Chron/Subject/Medlin's File/Hold;NOA-30 Interps;NOA-30 Redbook(3)

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