Interpretation ID: 1983-2.15

TYPE: INTERPRETATION-NHTSA

DATE: 06/06/83

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Fiat Motors of America Inc. -- Alberto Negro, Fiat Research and Development

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. Alberto Negro Fiat Research & Development - USA Branch Fiat Motors of North America, Inc. Parklane Towers West, Suite 1210 Dearborn, Michigan 48126

Dear Mr. Negro:

This is in reply to your letter of May 9, 1983, to Mr. Vinson of my staff with respect to conformance of a planned stop lamp design with Federal Motor Vehicle Safety Standard No. 108, Lamps Reflective Devices, and Associated Equipment.

The design comprises two compartments separated by a reflex reflector. One of the compartments will meet the photometric requirements for a stop lamp, in your judgement. The other will not, but in conjunction with the first compartment "the requirements can be met." You have asked if this arrangement is acceptable pursuant to paragraph S4.1.1.6 which allows photometric requirements to be met by a combination of compartments or lamps.

Paragraph S4.1.1.6 is intended to cover replacement stop lamps for vehicles manufactured between January 1, 1973, and September 1, 1978, when the SAE J586b, September 1966. As such, its requirements are not relevant to your concerns.

However, SAE J586c, August 1970, whose requirements do apply to stop lamps, appears to permit your design. Under paragraph 3.1, where the distance between filament centers of two stop lamps does not exceed 22 inches (presumably your design) the photometric readings of both lamps must be combined to meet the photometric requirements of Table 1 of J586c applicable to two lighted sections. However, the combined candela must not exceed the specified total of 360 for two lighted sections.

I hope this answers your questions.

Sincerely,

Frank Berndt Chief Counsel

May 9, 1983

Mr. Taylor Vincent Office of Chief Counsel Department of Transportation NHTSA 400 7th Street, S.W. Washington, D.C. 20590

Subject: FMVSS 108 Combination Tail Light Assembly

Dear Mr. Vinson:

Please find enclosed a drawing of a combination rear taillamp assembly that Ferrari would like to use on a model to be imported into the United States beginning with model year 1985 or 1986. Since this assembly is a departure from the round light assemblies customarily seen on the rear of the Ferrari vehicles, there is some minor concerns regarding the stop light portion of this assembly.

The lower left compartment of the assembly which is labeled "Sector II" and outlined in red is a stop light with a 32 candle power lamp. This sector by itself will meet the photometric requirements for a stoplamp. The lower right compartment which is labeled "Sector I" and having a 4 candlepower lamp while the second lamp is a dual filament lamp used as a parking/stop light. The parking light has a 32 candlepower rating. This sector of the assembly will not meet the photometric requirements by itself but in conjunction with "Sector II" the requirements can be met.

We have reviewed paragraph S4.1.1.6 of FMVSS 108 which states impart "the photometric requirements may be met by a combination of compartments or lamps" (emphasis added) and, therefore, we have concluded that Ferrari would be in compliance with the stop light requirements of Standard 108.

We are kindly requesting that NHTSA review the drawing and our interpretation of paragraph S4.1.1.6 and notify us if our conclusions that Ferrari would be in compliance with the stop light requirements of Standard 108.

We are kindly requesting that NHTSA review the drawing and our interpretation of paragraph S4.1.1.6 and notify us if our conclusion that Ferrari would be in compliance with Standard 108 is correct.

Sincerely yours, Alberto Negro