Interpretation ID: 1985-02.6

TYPE: INTERPRETATION-NHTSA

DATE: 03/28/85

FROM: AUTHOR UNAVAILABLE; Jeffrey R. Miller; NHTSA

TO: Mr. Gordon Bonvallet

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. Gordon Bonvallet Manager, Photometric Division ETL Testing Laboratories, Inc P.O. Box 2040 Cortland, NY 13045-2040

Dear Mr. Bonvallet:

This is in reply to your letter of February 13, 1985, to this Office asking whether the agency intended to eliminate the maximum allowable value for parking lamp candlepower in the amendments of November 26, 1984 which established Figure 1b.

Thank you for calling this matter to our attention. The amendment appears to have the effect you ascribe to it, though it was not the agency's intention that it do so. The maximum values of SAE J222 December 1970 are those that should apply, and we shall reinstate them in the near future.

Sincerely,

Original Signed By

Jeffrey R. Miller Chief Counsel

February 13, 1985

Office of Chief Counsel National Highway Traffic Safety Administration 400 Seventh Street, S.W. Washington, DC 20590

Gentlemen:

Subject: Interpretation of Rule Making 49CFR Part 571 (Docket No. 83-12: Notice 2)

Figure 1b in the reference Docket shows a minimum allowable candlepower value of 4.0 for a one section "Parking" lamp. No maximum is indicated.

Is the intent to eliminate the allowable maximum candlepower for parking lamps or should the maximum values as listed in SAE J222 Dec. 70, referenced in FMVSS 108, be used? (SAE J222 JAN77 eliminated the maximum values.)

Very truly yours,

Gordon Bonvallet, Manager Photometric Division

GB/mm