Interpretation ID: nht90-1.76

TYPE: INTERPRETATION-NHTSA

DATE: 03/19/90

FROM: SHUICHI WATANABE -- GENERAL MANAGER AUTOMOTIVE LIGHTING ENGINEERING CONTROL DEPT. STANLEY ELECTRIC

TO: ERIKA Z. JONES -- CHIEF COUNSEL DEPARTMENT OF TRANSPORTATION NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 05/31/90 FROM STEPHEN P. WOOD -- NHTSA TO SUICHI WATANABE; REDBOOK A35; STANDARD 108

TEXT: We are now developing the following new combination rear lamp which we would like to know whether it is permitted under FMVSS No. 108 or not.

Transformation Lamp

Characteristics: In this new lamp, the color and lighted area varies as shown in the figures below.

i) When tail lamp and/or stop lamp are activated, the whole lens luminous area (1, 2, 3) emits red light. When turn signal lamp is activated, the red light on the turn signal lamp area (1) disappears, and the amber light is emitted. RED RED RED --> AMBER RED RED 1 2 3 1 2 3

ii) In the same manner, when the back up lamp is activated, only the area for the back up lamp (3) changes its color from red to white. RED RED RED --> RED RED WHITE 1 2 3 1 2 3

iii) And when the turn signal lamp and reversing lamp are activated simultaneously, the turn signal lamp and back up lamp area (1 and 3) change their color as follows. RED RED RED --> AMBER RED WHITE 1 2 3 1 2 3

The requirement of photometric and lighted area for each lamp function comply to FMVSS No. 108 and related SAE Standards. As for stop and tail lamp, when 3 lamps (area 1, 2 and 3) are activated, comply to 3 compartment requirement, and when 1 lamp (area 2) is activated, complies to 1 compartment requirement of FMVSS No. 108.

Kindly let us have your advice whether the above new combination rear lamp is allowed or not as soon as possible.