Interpretation ID: 86-4.10

TYPE: INTERPRETATION-NHTSA

DATE: 07/09/86

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Rolf Seiferheld

TITLE: FMVSS INTERPRETATION

TEXT:

Service & Technical Bitter Automobile of America, Inc. 401 Willowbrook Lane West Chester, PA 19380

Dear Mr. Seiferheld:

This responds to your letter asking about 49 CFR Part 581, Bumper Standard. We apologize for the delay in our response. You stated that you are considering integrating fog-taillight assemblies in the rear bumper of a car and asked about relevant requirements. You noted in your letter that section S4.1.3 of Federal Motor Vehicle Safety Standard No. 108 (49 CFR 571.108) states that "(n)o additional lamp, reflective device, or other motor vehicle equipment shall be installed that impairs the effectiveness of lighting equipment required by this standard." You stated that this paragraph seems to be relevant but that it is unclear to you.

Both Part 581, Bumper Standard, and Safety Standard No. 108, Lamps, Reflective Devices( and Associated Equipment, are relevant to the location of fog-taillamp assemblies in the rear bumper. Fog lamps are lighting devices that are not covered by Standard No. 108. Therefore, two questions must be asked: are they permissible, and if so, may they be combined with items of lighting equipment required by Standard No. 108. Under section S4.1.3, quoted above, fog lamps are permissible provided that they do not impair the effectiveness of the lighting equipment that the standard requires. In this instance, the question cannot be answered without reference to whether its combination with the taillamp is permitted, for from the photo and drawing submitted, both appear combined in a single housing incorporating, we assume, one filament for each function. Both lamps are "position lamps", indicating the presence of the vehicle in the roadway ahead to a driver who is following behind. The fog lamp is intended to be activated under extreme conditions of reduced visibility, and hence, would appear to increase the effectiveness of the taillamp rather than impair it. Section S4.4 of Standard No. 108 prohibits combining taillamps only with clearance lamps (not required lighting equipment for passenger cars), and thus combining the taillamp and fog lamp functions are permissible. Section S4.3.1.1 of the standard specifies, among other things, that no part of the vehicle may prevent a taillamp from meeting its photometric output at specified test points. Further, a taillamp located in the bumper must also meet the visibility requirements of SAE Standard J585e Tail Lamps (Rear Position Lamps), September 1977, incorporated by reference in Standard No. 108. Pursuant to Paragraph 4 of J585e taillamps must be visible through a horizontal angle from 45 degrees to the left to 15 degrees to the right; to be considered visible, the lamp must provide an unobstructed projected illuminated area of outer lens surface (excluding reflex), not less than 2 square inches measured at 45 degrees to the longitudinal axis of the vehicle.

Finally, Part 581 Bumper Standard specifies requirements for the impact resistance of vehicles in low speed front and rear collisions. Vehicles must be capable of meeting certain damage criteria, following specified test impacts. Among other things, lamps must be free of cracks and comply with applicable visibility requirements of section S4.3.1.1 of Standard No. 108 following the impacts.

I hope this information is helpful.

Sincerely,

Erika Z. Jones Chief Counsel

November 18, 1985

Chief Counsel Jeff Miller National Highway Traffic Safety Administration 400 7th St., Southwest NASSIF Bld., Rm. #5219 Washington, D.C. 20590

RE: CFR 49, PART 581 BUMPER STANDARD

Dear Mr. Miller:

This is an Informal inquiry concerning the above referenced subject. Bitter Automobile of America, Inc. is the national importer of the Bitter SC automobile.

This Inquiry is in regard to the configuration of the rear bumper assembly of our automobile. In the past we have had a full face bumper bar without any light assemblies incorporated. However, I have been asked by Bitter K.G. GmbH Engineering staff what the regulations are of incorporating fog-taillight assemblies in the bumper; e.g. integrated into the rear bumper (see attached photograph and drawing). In consulting the Motor Vehicle Standard, No. 108, Part 571; S 108-7 , S 4.1.3, it states:

"No additional lamp reflective device or other motor vehicle equipment shall be installed that impairs the effectiveness of lighting equipment required by this standard."

This paragraph seems to relate to what we are contemplating, but is not clear to me. I kindly ask if the above could be feasible to change to a new style bumper.

I hope to hear from you soon and thank you for your time.

Sincerely,

Rolf Seiferheld Service & Technical

Enclosures

RS/red