Interpretation ID: 77-2.29

TYPE: INTERPRETATION-NHTSA

DATE: 05/05/77

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: D. G. Moore - Dry Launch

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of April 7, 1977, asking for a clarification of S4.3.1.1.1 of Standard No. 108. Your initial question of December 27, 1976, was not clear to us hence the reason my answer of March 4, 1977, caused you some confusion.

The diagram in your letter of April 7 clearly depicts the exemption provided by S4.3.1.1.1 for the specific reasons therein, that when a clearance lamp indicating overall width is not located on the rear of a vehicle it need not be visible at 45 degrees inboard. As the only required points of photometric measurement of a clearance lamp so located are to the rear and at 45 degrees outboard, the lamp need not be visible at any point in the 45 degree arc depicted in your letter.

SINCERELY,

DRY LAUNCH

April 7, 1977

Frank Berndt Acting Chief Counsel U.S. Department of Transportation National Highway Traffic Safety Admin.

Refering to your letter of March 4, 1977, #N40-30 (ZTV) the last two paragraphs dealt with my question - if it were permissible to eliminate photometric requirements in the "shaded" area provided for in the November 1975 amendment (S4.3.1.1.1). I'm afraid your answer was not clear to me and I can't say if you said it was permissible or not. Would you please clarify.

Dennis G. Moore

Does this area have photometric requirements when applied to the O.E.M. level?

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