Interpretation ID: 20132.ztv

Mr. Shigeyoshi Aihara
Project Manager
Regulation and Compliance
Engineering Administration Department
Ichikoh Industries, Ltd.
80 Itado Ishehara City
Kanagawa Pref.
250-1192 Japan

Dear Mr. Aihara:

This is in reply to your letter of June 10, 1999, presented at a meeting with NHTSA representatives that day, asking for an interpretation of S5.1.2 of Federal Motor Vehicle Safety Standard No. 108. I am sorry that we were unable to provide you a response by July 6 as you requested in your letter of June 28 to Taylor Vinson of this Office.

Your company has developed a new rear turn signal lamp, consisting of an outer plastic lens, an inner cap, and an uncolored filament bulb. The color of the lens is "pale (light) pink color, and, this plastic material complies with the requirements of SAE J576c . . . excluding the color requirement." You tell us that the trichromaticity coordinates of the plastic material used in the outer lens do not fall within either the red or the white areas of the chromaticity chart of SAE J578c. However, when illuminated, the lamp provides an amber color that fall within the coordinates specified in SAE J578c. You have asked whether this design is acceptable under S5.1.2 relating to plastic materials used in optical parts of motor vehicle lighting devices.

Although this does not affect our answer to your question, please note, in Standard No. 108, that SAE Recommended Practice J576c of 1970 has been replaced by SAE J576 JUL91 as the applicable standard for plastic materials used in lighting devices. However, J578c remains the Federal standard for color.

We regret to inform you that this design is not acceptable. Although S1, Scope, of SAE J578c states that "The specification applies to the overall effective color of light emitted by the device," regardless of the color of its lens, both SAE J576 JUL91 and Standard No. 108 apply the color requirement to plastic components of lamps as well. S5.1.2(e) of Standard No. 108 requires the trichromatic coordinates of the plastic samples, tested according to that paragraph, to conform to the requirements of SAE J578c. Paragraphs 4.1 and 4.2.2 of SAE J576 JUL91 also require conformance of plastic samples to the chromaticity coordinate requirements of SAE J578c. This standard specifies color coordinates only for red, white, yellow (amber), green, and blue. Because the lens of your lamp does not meet any of the coordinates of SAE J578c, Standard No. 108 does not permit its use.

At the meeting, we noted that the iner lens was a greenish color. It, too, must comply with the color coordinate requirements of paragraphs 4.1 and 4.2.2 of SAE J576 JUL91.

At that time, you also asked if it were acceptable to use a plastic fabricated from the mix of two resins, each of which complied with the requirements of SAE J576. You cannot assume, when two complying resins are blended, that the resulting plastic will also comply with SAE J576 JUL91, and we recommend that you test the blended plastic to ensure that it meets all the specifications of S5.1.2 and SAE J576 JUL91. This would be the case whether it was the intent to create a new color, or whether the rejected molded parts are reground and plastics of differing compositions are mixed and recycled into newly-molded lamp lenses. As we said in the preamble to the 1995 final rule amending S5.1.2, "it is incumbent upon the vehicle or equipment manufacturer . . . not to change the composition of the plastics materials [obtained from the plastics manufacturer] in a manner that would cause it to be noncomplying." 60 FR 46066, copy enclosed.

Sincerely,
Frank Seales, Jr.
Chief Counsel
Enclosure
ref:108
d.8/27/99