Interpretation ID: 1985-02.37

TYPE: INTERPRETATION-NHTSA

DATE: 05/30/85

FROM: AUTHOR UNAVAILABLE; Jeffrey R. Miller; NHTSA

TO: Mr. John K. Park

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. John K. Park Consultant, Hyundai Motor Company 7314 Nineteen Mile Road Sterling Heights, Michigan 48074

Dear Mr. Park:

This is in reply to your letter of May 3, 1985, asking for an 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 rear 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 to 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

Enclosure

May 3, 1985 Mr. Jeffrey R. Miller Chief Counsel National Highway Traffic Safety Administration Room 5219 400 Seventh Street Southwest Washington, D.C. 20590

Dear Mr. Miller.

Regarding FMVSS No. 108: Our High Mounted Stoplamp is obscured slightly by the rear window wiper arm according to our current design. The design ensures, however, the effective projected luminous area exceeding 4.5 square inches satisfactory to S4.1.1.41.

Do you consider the rear wiper arm described above as an obstruction to the lamp: We need a correct interpretation from you. I am including a sketch copy for your reference.

Sincerely yours,

John K. Park Consultant to Hyundai Motor Company

JKP/bks

encl.