Interpretation ID: 1985-02.5

TYPE: INTERPRETATION-NHTSA

DATE: 03/28/85

FROM: AUTHOR UNAVAILABLE; Jeffrey R. Miller; NHTSA

TO: Mr. Robert M. Levy

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. Robert M. Levy Manager, Design Engineering Abex Corporation Signal-Stat Division P.O. Box 438 Somerset, New Jersey 08873-3492

Dear Mr. Levy:

This is in reply to your letter of February 25, 1985, to Frank Berndt, the former Chief Counsel of this agency, asking for clarification of an interpretation of Safety Standard No. 108 that tnis agency furnished last year to Wesbar Corp.

On May 16, 1984, Wesbar asked whether the correct minimum effective luminous lens area on stop lamps and turn signal lamps was 8 square inches or 12 square inches, when intended for use on trailers whose overall width is 80 inches or greater. This office advised Wesbar on July 3, 1984, that, as specified in SAE J586c for stop.lamps and SAE J588e for turn signal lamps, the answer was 8 square inches. Your letter calls to our attention the fact that these SAE standards require each stop and turn signal lamp to have a minimum of 12 square inches in those vehicle configurations where two stop or turn signal lamps are mounted on the same side of the vehicle and are closer to each other than 22 inches.

Thank you for calling this oversight to our attention. Indeed, SAE J586c and J588e establish this exception to the general minimum requirement of 8 square inches. We are furnishing a copy of this letter to Wesbar and apologize for any confusion that the earlier letter has caused.

Sincerely,

Jeffrey R. Miller Chief Counsel

cc: Mr. C.I. Nielsen III Vice President - Marketing Wesbar Corporation Box 577 West Bend, Wisconsin 53095