Interpretation ID: 21718.ztv

Michel Luc Bataini, Eng. Jr.
DBM Reflex Enterprises Inc.
1620 Dagenais Blvd. West
Laval, Quebec H7L 5C7
Canada

FAX 450-622-3017

Dear Mr. Bataini:

This is in reply to your fax of May 25, 2000, with questions about S5.4 of Federal Motor Vehicle Safety Standard No. 108. This paragraph specifies that "Two or more lamps, reflective devices, or items of associated equipment may be combined, if the requirements for each lamp, reflective device and item of associated equipment are met . . . ."

It is your assumption that "a front side reflector made of 2 different items is legal only if both item individually meet the regulation." You then asked "if two reflective devices (each device do not meet the regulation by itself) molded separately, are assembled on the same housing, then, would that be legal? If not, molding those two items together and then assembling them with the housing would be legal?"

S5.4 allows a manufacturer to combine two lamps, reflective devices, or items of motor vehicle lighting equipment provided that each lamp, reflective device, or item of motor vehicle equipment used in the combination complies with the requirements of Standard No. 108 which apply to it. You have informed us that neither of the reflective devices in your design comply with Standard No 108's requirements, presumably those for a front side marker reflector. This means, then, that S5.4 does not apply to your design, and that we must answer your letter without reference to S5.4.

The drawing accompanying your letter shows that the reflective devices to which you refer would be incorporated into a headlamp housing and be visible from the side when light is reflected from them. The proper question, then, is whether Standard No. 108 permits a front side marker reflector to consist of two reflective devices molded separately and assembled on the same housing. The answer is yes, provided that when assembled on the housing they meet the requirements of SAE Standard J594f Reflex Reflectors January 1977, principally those relating to photometry. It follows then, that two reflective devices may be molded together and mounted on the same housing if they comply with SAE J594f 's requirements for reflex reflectors as mounted on the housing.

You will note that some rear lamp units are designed so that compartments that are lit are separated by multiple red reflex reflective devices, neither of which alone may be sufficient to comply with the rear red reflex reflector requirements of Standard No. 108, but, taken together, meet the standard. In this situation also, the reflex reflectors are not "combined" within the meaning of S5.4.

If you have further questions, you may call Taylor Vinson of this Office (202-366-5263).

Sincerely,
Frank Seales, Jr.
Chief Counsel
ref:108
d.7/19/00